Crystal Palace Park Enabling Development and Financial Viability Assessment. Prepared on behalf of London Borough of Bromley Reference: 60553431-REP-ZZ-006 Rev 01 Date of Report: 9 September 2020 Public Issue Executive summary Proposed The proposed enabling development at Crystal Palace Park includes a sensitive proposal Enabling for residential development on the edge of the park. The release of part of the park for Development residential development will provide essential funding to help deliver a significant proportion of the restoration and repair which was originally proposed in the 2007 Masterplan. The 210 units proposed at Rockhills and Sydenham Villas combined are considered to be an optimised solution to contribute towards significant conservation benefit to the park. The proposed scheme comprises 140 units at Rockhills Gate (55 x 1 beds, 83 x 2 beds, 2 x 3 beds) and 70 units at Sydenham Villas (9 x 1 beds, 61 x 2 beds). The Numbers and Summary Costs (assuming single Costs (assuming NPV of of the Seven Summary of Costs unconditional land receipt profiled land receipts) Tests Total Cost of Regeneration £40,000,000 £40,000,000 Expected Grants National Lottery Heritage Fund £5,000,000 £5,000,000 National Lottery Community Fund £1,500,000 £1,500,000 Historic England £1,000,000 £1,000,000 Other Grants £6,775,000 £6,775,000 Total Expected Grants £14,275,000 £14,275,000 Other Income Other £1,000,000 £1,000,000 Crowdfunding £500,000 £500,000 Total Other Income £1,500,000 £1,500,000 Capital Receipts Rockhills Gate £13,047,875 £15,003,532 Sydenham Villas £8,025,216 £9,221,409 Total Capital Receipts £21,073,091 £24,224,941 Total Proposed Income £36,848,091 £39,999,941 Surplus/Deficit -£3,151,909 -£59 The summary table above, illustrates the two potential scenarios: 1) Where the land is sold unconditionally as a single up front land receipt (this is market value) and 2) Where land receipts are profiled and deferred over several years. The second scenario improves the net present value and therefore results in a negligible deficit for the project when compared to a single up front land payment. The Council therefore intend to pursue the Enabling Development Case │ London Borough of Bromley │ Page 2 Prepared on behalf of London Borough of Bromley │ 9 September 2020 profiled receipt scenario which is financially beneficial for the project and aligns land payments with the capital works programme. Historic England’s enabling development publication 1 provides both the policy itself and detailed practical guidance on enabling development’ for those seeking consent for enabling development. This is supplemented and simplified by Paragraph 202 of the NPPF which indicates that local planning authorities should assess whether the benefits of a proposal for enabling development, which would otherwise conflict with planning policies, but which would secure the future conservation of a heritage asset, outweigh the disbenefits of departing from those policies. The seven tests help ensure a rigorous approach by planning authorities to assessment. The seven tests which are set out in the Historic England guidance need to be met in order for the enabling development case to be sufficiently made. The policy is detailed below; Enabling development that would secure the future of a significant place, but contravene other planning policy objectives, should be unacceptable unless: a) It will not materially harm the heritage values of the place or its setting b) It avoids detrimental fragmentation of management of the place c) It will secure the long-term future of the place and, where applicable, its continued use for a sympathetic purpose d) It is necessary to resolve problems arising from the inherent needs of the place, rather than the circumstances of the present owner, or the purchase price paid e) Sufficient subsidy is not available from any other source f) It is demonstrated that the amount of enabling development is the minimum necessary to secure the future of the place, and that its form minimises harm to other public interests g) The public benefit of securing the future of the significant place through such enabling development decisively outweighs the dis-benefits of breaching other public policies. We have applied the seven tests to demonstrate the case for enabling development as a part of the Crystal Palace Park (CPP) Regeneration Plan. This is summarised from this report below; a) It will not materially harm the heritage values of the place or its setting The proposed sites are carefully located to preserve the heritage value and setting of the registered park and listed structures. They are: · On the periphery of the park along existing residential streets; · On previously developed residential land or developed land (Caravan Club); and · Outside the setting of listed structures. Development of these sites will restore the original historic features of the park including the built-up boundary of the park which existed from the mid to late 19th century and was lost following the Second World War and will open up areas in the north-west of the park currently inaccessible to the public. Development will also enabling capital to be spent on key works to the listed structures within the park, an endowment to support a sustainable business model for the park, a new not for profit management organisation and removal of key listed assets from the Heritage at Risk Register. b) It avoids detrimental fragmentation of management of the place 1 Historic England Publication ‘Enabling Development and the Conservation of Significant Places’ 30th September 2008 Enabling Development Case │ London Borough of Bromley │ Page 3 Prepared on behalf of London Borough of Bromley │ 9 September 2020 Detrimental fragmentation is avoided as the proposed enabling development sites are carefully located to preserve the heritage value and setting of the registered park and its listed structures. In order to ensure and promote coherence in management it is anticipated that the park will be transferred by LBB to a governing Trust. This Trust will employ a staff team dedicated to the management of CPP. Alongside maintaining CPP as a public park, the number and variety of yearly events and other activities will be increased and diversified with the aim to maximise commercial revenue. The management driven and controlled by the Trust will ensure a dedicated and coherent management and maintenance approach, similar to that of the Royal Parks which will ensure integration and cohesion for CPP. c) It will secure the long-term future of the place and, where applicable, it’s continued use for a sympathetic purpose The proposed enabling development represents approximately 50% of the funding solution for the capital works enshrined within the CPP Regeneration Plan. The new Business Plan for the future operation and management of the park and these spaces has been developed. The overall objective of the Regeneration Plan is to regenerate CPP and secure its long- term future through a sustainable business model. This will deliver an improved park, with the ability to generate its own income. It is linked to the development of a new governance model for the park in the form of a Trust. Future management of CPP is proposed to be through a hybrid approach, whereby the Trust employs a lean, but expert management team that, outsources most day-to-day operations to specialist providers. The Business Plan identifies a business model that is predicated on an evolving programme of special events and activities (large and small, community and commercial). The Business Plan includes a baseline financial summary showing potential income and expenditure for the Trust which generates a small forecast deficit of the stabilised business of circa £107,000. This deficit of £107k is being bridged through the interest on a capital endowment. This model assumes a LBB subsidy that tapers to c. £125,000 per annum by 2026/27. Therefore, a capital endowment of c. £4.3 million is assumed to generate the return needed to bridge the deficit. d) It is necessary to resolve problems arising from the inherent needs of the place, rather than the circumstances of the present owner, or the purchase price paid Having already suffered from steady decline under the previous management regime, LBB inherited a park that required a significant level of investment in terms of its ongoing management and maintenance. The park’s scale, complex landscape and its significant number of important but damaged heritage features remain a challenge for local authority budgets and expertise. With pressure on LBB’s budgets increasing, LBB is not in a position to commit the level of funding required to ensure that the park does not continue to deteriorate. Furthermore, if this scheme does not go ahead, LBB’s aspiration to generate and ring-fence additional funds for the park via a community trust governance model cannot be brought to fruition. The community trust model is dependent on the delivery of capital improvements which conserve the heritage, improve the park as a destination for visitors, and create income generating opportunities that will help off-set ongoing revenue costs for the park. e) Sufficient subsidy is not available from any other source Enabling Development Case │ London Borough of Bromley │ Page 4 Prepared on behalf of London Borough of Bromley │ 9 September 2020 The total cost of the Regeneration Plan is currently £40 million. LBB has been actively pursuing other sources of funding in order to provide a balanced funding solution for the proposed works of conservation and repair which form a part of the Regeneration Plan. The proposed enabling development would deliver circa 50% of the funding requirement with estimated land receipts in the region of £21.1-£24.2 million depending on the disposal route.