Fred Brown - Development Control
Greenwich Council
Directorate of Regeneration, Enterprise and Skills
Crown Building 5th Floor
48 Woolwich New Road
London SE18 6HQ                                                                                               13th January 2010

Dear Mr Brown

Application 09/2598/F and 09/2599/L - temporary use of land at Greenwich Park, National Maritime Museum, Old Royal Naval College and Blackheath Circus Field for the Equestrian and Modern Pentathlon Events (including the Test in 2011) for the London 2012 Olympic and Paralympic Games

Thank you for your letter dated 9th December 2009 notifying the Blackheath Society of the above planning and listed building consent applications.

In mid-2008, the membership of the Society resolved to object to the use of Greenwich Park for the one-day Cross Country element of the Equestrian Events, out of concerns about damage to the fabric of the Park and to the reduced access to the Park generally.

At the same time, members also tasked the Management Committee to enter into a dialogue with LOCOG with a view to mitigating their concerns.

As you are aware, the Society, with other local amenity organisations, subsequently engaged in a constructive exchange of ideas with LOCOG. This has resulted in improvements to LOCOG’s proposals which are reflected in the present submission.

However, despite the fact that changes have been made, we must oppose the application submitted by LOCOG on a number of grounds.

Although the application material is extensive, it is far from being specific or complete on many important issues (eg the arena design, remediation proposals, Circus Field) and, in some areas (eg the arena design), the documentation is contradictory.

However, if the Council were to be minded to grant planning permission, notwithstanding the many concerns that there are with the application, we believe that such consent should be subject to a whole range of conditions to cover all the instances where decisions have yet to be made. 

Furthermore, many of the specific omissions in the documentation are of such significance that the conditions should be the subject of further involvement of both statutory consultees (especially English Heritage and Natural England) and interested parties such as ourselves, with a final decision being made by the Planning Board.

If permission were to be granted, it is clear that this proposal would carry with it major risks, such as the possibility that the remediation measures may not be effective, or executed properly. We therefore believe that the Council should require some sort of robust performance guarantee from LOCOG given that this organisation has a limited life span. By this we mean a performance bond backed by money sufficient to restore the Park to its original state. The amount should be agreed with the Royal Parks.

Legacy was a key part of the original bid, and we consider that the documentation in this respect is significantly lacking. We believe that the Council should require LOCOG to commit to a much more significant remediation of the Park and an improved restoration of Blackheath Circus Field - in both cases beyond simply aiming to return it to its previous state - as part of the Legacy arrangements.

We are further particularly about the submission in the following areas (please see Annexes for details)

Test Event

• Information should be provided on this important aspect of the proposals to the same degree as for the 2012 events proper.

Greenwich Park

• The documentation underestimates the threats to the existing acid grasslands and their habitats. The commitment to their restitution should also be more ambitious/generous.
• The treatment and management of other grasslands has not been properly assessed.
• Questions remain about the damage to trees within the Park.
• The impact of the cross-country course on sites of archaeological importance is underestimated.

The Arena

• The lack of detail on alternatives for the sub-structure for the Field of Play makes evaluation impossible (although option 3 at least would appear to be unacceptable), and the fact that they have still not been tested is a serious concern.
• The apparent lack of access to the arena area over 2011/2012 appears excessive.

Transport

• There needs to be an assessment of how public transport will cope with spectator travel. The submission is silent on the effect of introducing an Olympic Lane in the Blackwall Tunnel.
• The implications of introducing direct coach services need further consideration, as does the use of taxis and private hire vehicles.

Blackheath Circus Field

• An early resolution of the legality of using Circus Field, brought to the attention of both LOCOG and the Council in our letter of 4th December 2009 to Ms Ney, is required.
• Only limited information has been provided on the impact of the temporary installations on Circus Field, both at the time of the 2011 Test Event and the 2012 Events proper.
• Reinstatement should allow for improvement to the surface and the Duke Humphrey spur.
• The impact of construction traffic using the Blackheath Gate entry to the Park has not been considered.

A further concern which cuts across a number of the subjects covered in the Annexes referred to below is the number of spectators for the Cross Country Event (75,000), especially with regard to transport issues and the risk of damage to the Park. We believe that this number should be significantly reduced. 

We attach a series of Annexes on each of the detailed topics listing questions which we believe should be resolved before the application is determined.

We may wish to make a further submission in the extended consultation period up to 27th January 2010.

A copy of this letter and the attachment is being sent to Neil Smith at LOCOG.

Yours sincerely

Howard Shields

Chairman

Encl:       Annexe AThe Test Event

              Annexe B Greenwich Park

              Annexe C The Arena

Annexe D Transport

Annexe E Blackheath Circus Field 

Cc Neil Smith, LOCOG