Transport for London Commercial Development

FutureMerton Team Commercial Development

London Borough of Merton Transport for London London Road 7Y3, Palestra, Morden SM4 5DX 197 Blackfriars Road London SE1 8NJ

By email: [email protected] Email: [email protected]

29 January 2021

Dear Sir/Madam,

RE: Merton Local Plan, Stage 2a consultation

Thank you for the opportunity to comment on the London Borough of Merton’s (LBM) draft Local Plan (Stage 2a). Please note that the responses below represent the views of the Transport for London Commercial Development (TfL CD) planning team in its capacity as a landowner in the borough only, and do not form part of any representations that may be made by TfL in its statutory role as a transport operator and highway authority for London or in respect of land-use planning and transport policy matters. Our colleagues in TfL Spatial Planning have provided a separate response to this consultation in respect of TfL-wide operational and land-use planning / transport policy matters as part of their statutory duties.

TfL CD Introduction

TfL owns around 5,700 acres of land across London, including buildings, railway and bus stations, highways, rail lines and adjacent land, and work-sites. TfL CD have prepared an ambitious commercial strategy that considers TfL’s entire estate and we are looking at creative ways to make the most of these landholdings. Central to our work is supporting the Mayor of London’s objectives of delivering significant long-term revenues from development to reinvest in the transport network and providing new housing and, importantly, genuinely affordable homes across the capital.

TfL owns or controls land with significant potential to contribute towards new homes, affordable housing, workspace and transport improvements in the LBM area. Given TfL CD’s land interests in the area and the major benefits that development can deliver, particularly in terms of new housing provision, it is critical for there to be a Local Plan in place that will enable such opportunities to be optimised. Accordingly, our representations in respect of the Merton Local Plan are set out below.

TfL CD Representations

A general comment is that a number of the policies seem quite repetitive; there should be a focus on making sure the policies are succinct in line with planning practice guidance and that they are also clear on how they will be delivered and achieved.

There also needs to be consistency in the way that policies are set out and numbered, as well as a general review of the policies for spelling, grammar etc.

Good Growth Strategy

Prioritising walking, cycling and public transport The Mayor’s Transport Strategy advocates that 80% of trips across London by 2041 should be made by public transport, and TfL CD is committed to delivering development opportunities which help to maximise public transport use and minimise car-dependent development. As such, this objective is supported.

It should be noted that promoting sustainable forms of transport is not just about tackling obesity and reducing air pollution. The benefits also include other health outcomes such as reduced risk of cardiovascular disease, improved mental wellbeing, stress reduction, as well as the creation of a safe city through more people, as opposed to vehicles, on the streets and the potential to address physical and social barriers. More information on the benefits of sustainable forms of transport can be found in the TfL Healthy Street for London document (see pg. 18 – 24 in particular).1 The London Plan paragraph 10.5.2 notes that Merton has a relatively high level of people travelling to destinations by bike as compared to other parts of London and this should be reflected.

Adapting to climate change The intent to look to learn lessons and seek opportunities from Covid-19 is a laudable aim, however it is not clear what is meant by this in providing “a new baseline of what can be achieved”. The key point should be that a certain level of flexibility will be necessary as part of new development to enable development to suitably adapt to future changes.

Good growth strategy The key priorities for delivering growth do not seem to refer to development which will attract new businesses into the borough, instead the emphasis appears to be more on businesses staying or expanding within the Merton. Opportunities for new businesses to locate within the borough should also be encouraged and supported to ensure a robust, diverse and dynamic economy.

Delivering Growth The objectives of balancing growth against protecting what makes the borough special is understood, however the wording seems to indicate that distinctive established residential character would be expected to be protected and enhanced. It is considered that this wording is not in line with the National Planning Policy Framework 2019 (NPPF) which notes that planning policies should take local circumstances into account and should reflect and be sympathetic to local character rather than it necessarily being protected.

Density TfL CD supports the broad aims of this objective; to deliver high quality and higher density residential schemes to make more efficient use of land, particularly within areas having good, accessible public transport. The optimisation of sites, making efficient use of land and provision of higher density development will contribute to a significant increase in housing provision to meet the needs of the borough.

1 http://content.tfl.gov.uk/healthy-streets-for-london.pdf

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Mixed use developments There is reference to multi-site proposals being planned in a coordinated manner and the need to prove that there is a clear public benefit to this approach. Schemes delivered under a single ownership (particularly on larger sites) should also be planned in a coordinated manner and the planning balance also assessed, so it is not clear why this is particularly highlighted here for multi-site proposals.

Good Growth Morden – the first bullet point notes that a balanced mix of uses will be sought. The list should acknowledge that town centres are continuing to evolve and must be flexible to reflect this, especially since the Covid pandemic is likely to accelerate structural changes in shopping habits and provision. Also, there may be potential for other commercial uses in addition to those listed including leisure uses and a night time economy which should also be supported.

Climate Change It is acknowledged that a robust approach is required to climate change. However, policies CC8.11 and CC8.12, and CC8.15 seem relatively onerous and should be reviewed. For Policy CC8.15 the requirement for non-residential of 500sqm GIA and above to achieve BREEM excellent should be caveated to allow for where it can be demonstrated that it is not technically feasible or viable to do so.

Policy DF1 in the publication London Plan prioritises affordable housing and transport improvement above all else where viability is an issue.

Places and spaces in a growing borough

Policy LP D5.1 and Policy D5.2 Policy LP D5.1 criterion c states that public realm should be designed with priority for pedestrians and cyclists in mind and encourage greater walking and cycling around the area. Policy D5.2 also sets out the requirement for proposals to create urban layouts based on a permeable and easily navigable network of recognisable streets and spaces that link in seamlessly with surrounding development and facilitate walking, cycling and use of public transport (although criteria a and b do seem to be repetitive in part). TfL CD support this aim to achieve this significant modal shift.

More detailed reference could be made, however, to the potential of optimising densities and building heights in areas with a high PTAL and/or adjacent to transport hubs, in line with publication London Plan objective GG2.

Policy LP D5.1 – Tall Buildings TfL CD is supportive of tall buildings being allowed in the town centre of Colliers Wood, Morden and Wimbledon.

However, the policy should also allow for tall buildings within transport hubs and areas of high transport accessibility where development densities may be optimised in line with the publication London Plan, for example in South Wimbledon.

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Policy D5.3 – Design considerations in all developments Criterion iii requires that trees and other landscape features are protected. This criterion should be removed, this point is covered in Policy 08.4 – Protection of Trees and the criterion conflicts with Policy O8.4 as it seems to indicate that all trees and landscape features are protected rather than being based on a qualitative assessment.

Policy D5.5 – Managing heritage assets The test of ‘substantial harm’ referenced in criterion c does not apply to non-designated heritage assets, rather paragraph 197 of the NPPF requires that the effect of an application on the significance of a non-designated heritage assets is assessed using a balanced judgement. Therefore, a distinction should be made between designated and non-designated heritage assets in the policy itself in line with NPPF paragraph 193 – 198.

Economy

Policy Ec7.1 – Economic Development Criterion 2c and 3e are not very clear about how they will be achieved, and the policy should recognise that in some scenarios there may no longer be the demand for one particular use and, subject to appropriate justification, redevelopment to other uses could be considered (this latter point also applies to Policy EC7.2a).

Criterion 2h is also not clear on how this will be achieved and what the exact expectation will be. This may also be covered off in Policy EC.4 anyway so could be removed from the policy to avoid repetition.

This policy should also refer to the potential for intensifying employment land uses, including the co-location of industrial uses with residential where suitable. Co-location is an innovative land use approach which can help protect existing industrial capacity, whilst also contributing towards meeting identified housing need through on-site residential development, promoting a creative and effective use of available land. TfL CD also believe that there are similar opportunities for the co-location of housing development with transport infrastructure e.g. ‘over station development’ at railway and bus stations and depots, which should also be included in the Local Plan.

Policy EC7.3 – Protection of scattered employment sites Part iii notes that proper marketing must be undertaken to justify the loss of scattered employment to residential uses for 30 months and this is considered an excessive amount of time. This should be amended to a minimum 12 months in line with the publication London Plan. This point also applies to Policy IN16.2.

The last paragraph also notes that the council will seek measures to mitigate against the loss of employment land and then gives an example. This is not considered an appropriate policy approach and the policy should be clear on what the mitigation measures would be for clarity.

Policy EC.4 – Local Employment opportunities Criterion c should identify what the minimum period is for jobs to be advertised for.

Policy EC7.5 – Merton’s town centres and neighbourhood parades Criterion iv requires that a window display is provided. This appears to be an overly onerous requirement, although clarification is requested on what a window display would constitute.

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If it is referring to active frontage then this criterion should be removed as this requirement is already covered elsewhere.

More generally, town centres are continuing to evolve, and they must be designed to be flexible to weather future changes. This must be recognised in relevant policies throughout the Local Plan, including this policy.

This policy/justification should reflect that the NPPF paragraph 85 states that planning policies should recognise that residential development often plays an important role in ensuring the vitality of centre and encourage residential development on appropriate sites. This could also be reflected in Policy Tc7.7, where the space above shops or above train stations may be suitable for residential development.

Town centre policies could go further to promote mixed use, residential led development in town centres, particularly adjacent to or above transport infrastructure. Policy could also refer to the potential for conversion and/or redevelopment of retail and other town centre uses to residential, including vacant units where the retail offer and function of the town centre is not detrimentally impacted as a result.

Policy TC7.9 – Culture, arts and tourism development This policy is referenced on the Local Plan consultation webpage but is not included in the document.

Green and blue infrastructure

Policy 08.1 – Open Space, Green Infrastructure and Nature Conservation This policy states that the Council will protect and enhance open spaces, green infrastructure and area of nature conservation. It should be made clear that this relates to open space with some value, otherwise this could be read as restricting development on all open spaces even if they have no specific value and redevelopment would be beneficial to the area. This would be in line with the NPPF glossary definition of Open space which defines the term Open space as ‘all open space of public value’. The same point applies to Policy 08.2 as well.

Policy 08.3 – Biodiversity and nature conservation As per paragraph 171 of the NPPF a distinction should be made between the different hierarchies of designation.

Criterion (c) should be worded more positively in line with paragraph 16 of the NPPF, rather than stating that development ‘will not be permitted’.

Policy 08.4 – Protection of Trees Criterion b expects development proposals to protect, retain and enhance trees, hedges and other landscape features of amenity value, on site and on adjoining land. The word ‘enhance’ indicates a requirement to improve the quality or amount of trees on a site and on adjoining sites, which is considered a relatively ambiguous requirement and also one which may not be within a developers control if the requirement relates to an adjacent site which they don’t have control over. It is suggested the word enhance is removed.

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Policy P8.11 – Improving air quality and minimising pollution It is suggested that criterion a is aligned with the publication London Plan policy S1.

Criterion f should more accurately reflect the NPPF, which does not preclude noise-sensitive development near noise generating land uses as long as the noise can be mitigated appropriately. This is particularly pertinent in the case of development near railway lines.

Housing provision

Policy H4.1 – Housing Choice It is noted that the affordable housing percentage will be based on number of units rather than habitable homes, and the reasoning behind this is provided in paragraph 4.1.28. The principle of seeking a straightforward planning system to assist the understanding of those outside the property industry is appreciated, however there still needs to be some more technical parts of the planning system to ensure that the planning system achieves key objectives. The reason for habitable rooms in the London Plan is to seek to ensure that a range of sizes of affordable homes can be delivered. The council’s evidence base for the affordable housing percentage should consider a habitable room approach to address concerns of the delivery of less affordable housing. It is suggested that the policy is changed from unit to habitable room to ensure consistency with the London Plan.

Policy H4.3 – Housing mix This policy notes that:

“Residential development proposals will be considered favourably where they contribute to meeting the needs of different households such as families with children, single person households and older people by providing a mix of dwelling sizes, taking account of the following borough level housing mix”

It should be clarified what is meant by ‘taking account of the following borough level housing mix’; it is not clear if this is the current make up of the borough or whether it is detailing what the needs of the borough are, based on a housing need assessment, although the justification text does indicate it is the latter.

In addition, the SHNA is already four years old and there may be implications for housing demands due to Covid-19 (I.e. more people moving out of central London to outer boroughs). As such, it may be appropriate to caveat in the policy that the latest housing data compiled by the borough should be used.

Policy H4.7 - Build to Rent TfL CD are supportive of the draft Local Plan’s inclusion of a policy on build to rent developments. However, we consider the proposed approach to be too onerous and should be reviewed. In particular, TfL CD have the following concerns:

Criterion c) Minimum of 3 year tenancies - A ‘minimum’ of 3 years is quite rigid. The Publication London Plan’s BtR policy wording is ‘longer tenancies (three years or more) are available to all tenants’ (Policy H11). TfL CD suggest the wording aligns to give greater flexibility, but the same mid-term view to tenancies.

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Criterion d) Covenants of 30 years - The Publication London Plan’s position on this is a minimum of 15 years (Policy H11). 30 years would not give an appropriate level of flexibility or align with the London Plan approach. The reference to clawback mechanisms in part h) should also be decreased to 15 years accordingly.

Criterion e) Security and professional management of homes - The Publication London Plan sets out that ‘this does not necessarily mean full-time dedicated on-site staff, but that all schemes need to have systems for prompt resolution of issues and some daily on-site presence’. TfL CD suggest the policy aligns with this and this is clarified. Security is quite a vague term and could be interpreted as personnel on site.

Criterion f) AH at 100% LLR tenure – TfL CD suggest there is flexibility in this being termed DMR.

Criterion j) Viability reviews - The approach should be consistent with the Publication London Plan.

Infrastructure

Policy IN6.1 – Infrastructure Criterion c states that the Council will require new development to provide for any necessary infrastructure. It is suggested that this wording makes it clear that this is necessary infrastructure as a direct consequence of that new development in line with paragraph 56 of the NPPF.

In addition, we would suggest that the policy should make specific reference to include sustainable transport infrastructure, to ensure that developments located in areas well served by public transport will be prioritised.

It should also be clarified that the reference to “necessary infrastructure” can relate to both existing infrastructure and planned infrastructure, to be provided as part of proposals. The justification section mentions transport infrastructure, but it should be included in the policy as well.

Transport and urban mobility

Policy T6.4 – Improving travel choice TfL CD support Policies T6.4, T6.5 and T6.6, particularly how these policies align with the objectives of the Mayor’s Transport Strategy, which sets out an expectation that development proposals support the Mayor’s strategic target of 80% of all trips in London being made by foot, cycle or public transport by 2041. TfL CD support the aim to achieve this significant modal shift.

The reference to Vision Zero is also supported, but it might be useful to provide more of an explanation of what Vision Zero is.

Criterion b notes that the council will encourage people to travel less. It is suggested that people travelling by sustainable modes of transport is not something that necessarily needs

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discouraging, and this point should instead be about encouraging people to travel less by motor vehicles.

Policy T6.7 and T6.8 Both of these policies refer to the potential for permit free development in higher PTAL areas, it is suggested that this reference is removed from T6.7 so as not to duplicate the point.

With regard to T6.8:

• Criterion d - is considered overly onerous to limit all retail and leisure development to short stay use. This should be considered on a case by case basis, although as per paragraph 10.6.21 of the publication London Plan this should be carefully managed so that it does not undermine the attractiveness of alternatives to the car. • Criterion g – there should be some guidance on what the inclusion of ‘sufficient capacity to accommodate increase recycling requirements’ might constitute. This seems quite an arbitrary requirement which would likely be difficult to account for. • Criterion j – it is unclear what is meant by ‘the Council will seek to repurpose kerb space for other uses’. If this is referring to conversion of car parking to other uses e.g. cycle parking, parklets, widened pavements, then this would be encouraged where appropriate.

Policy T6.9 – Supporting Transport infrastructure In our response to the previous Regulation 18 consultation we noted that criterion ai and aii appear to contradict each other. However, this has not been amended and our comments still stand; criterion a requires that all of the criteria are met but if the site no longer serves any operational need now or in the future (as per i) then equivalent alternative provision would not be necessary (as per ii). It is acknowledged that there could be a situation where the site in question is no longer required for operational use due to its obsolescence, but a more suitable replacement site is still needed, however, the wording should also apply when this is not the case.

Neighbourhoods

On a general note, it is considered that the layout of the site allocations in the previous Regulation 18 version of the draft Local Plan were much easier to follow than the current version.

Another general point is raised about how there is some repetition between the broader strategic policies and the site allocations, in particular Policy N3.3 and site allocation Mo4. Planning practice guidance outlines that plans should be succinct so policies should be reviewed in light of this. If repetition is maintained, then policies and site allocation that do have any repetition must ensure they are saying the same thing.

Policy N3.1 – Colliers Wood TfL CD generally support this policy.

Site CW1 – Baltic Close, 194-196 High Street Colliers Wood TfL CD generally support this site allocation.

Site allocation CW4 - Colliers Wood Station and 2-24 Christchurch Road

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TfL CD generally support this site allocation. The site is available and developable for residential or mixed use development, subject to feasibility studies.

Policy N3.3 - Morden Morden has been identified as one of the major growth and housing opportunity areas in south west London by the Mayor of London, TfL and the London Borough of Merton (LBM). TfL are a substantial landowner within Morden town centre and have identified land assets within this area as having the potential to deliver a substantial amount of development. LBM is also a substantial landowner with Morden Town Centre. Both organisations have been working together to identify the feasibility of potential aggregation of land assets to enable wider comprehensive regeneration proposals.

TfL CD are committed to investing in significant regeneration through intensified development. With respect to this, TfL CD strongly supports the strategic proposals for Morden town centre. In particular these are supported by the publication London Plan objective GG2 which sets out that those involved in planning and development should proactively explore the potential to intensify the use of land to support additional homes and workspaces, promoting high density development, particularly on sites that are well connected by public transport.

Due to the above, and as the town centre is designated as an area for housing intensification, TfL CD are particularly supportive of the requirement for high density development in order to intensify the use of the land at this key location.

It is important that the focus area includes the entire town centre so that a fully informed set of masterplan principles can be developed in order to establish a strong and robust policy framework in which to facilitate effective regeneration of Morden town centre. This should include areas that could come forwards as later phases in the future and areas that may not be developed per se, but which should form part of the specific Town centre context. As such, the approach to highlighting the site allocations and the Wider Morden Town centre area is supported.

TfL would like to continue to work productively with LBM to ensure an optimum policy and site allocation is presented in the final version of the Local Plan.

In terms of the policy wording itself, we have the following comments. Current policy is the wording in italics and suggested amendments to the policy are provided in red/struck through:

• “By focusing regeneration in the Wider Morden Town Centre Area, this plan-led approach will help to conserve and enhance the character and distinctiveness of the surrounding suburban Morden neighbourhood.”

As set out above in our comments on the Delivering Growth section, the objectives of balancing growth against protecting what makes the borough special is appreciated, however the wording seems to indicate that the character of the area would be expected to be conserved. It is considered that this wording is not in line with the NPPF which notes that planning policies should take local circumstances into account and should reflect and be sympathetic to local character rather than it necessarily being conserved. It is likely that a major redevelopment will have a noticeable impact on the character of the area, which does not have to necessarily be a negative thing, and as such a requirement to conserve the character could restrict potential.

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• b. Comprehensive regeneration of the whole Morden Regeneration Zone to optimise the delivery of new homes (including affordable homes), improve the streetscene and public realm, make it easier for all to get around, and support businesses and other appropriate uses within the Morden Regeneration Zone. Any proposal that hinders the delivery of comprehensive regeneration will be resisted;

• c. Improving the appearance, user experience and air quality of Morden by relocating the bus stands outside Morden underground station away from their current location to help create and creating healthier streets and a welcoming public space outside the Morden underground station entrance. Alternative bus stands should be designed and located to ensure there is no loss of capacity or operational efficiency;

• e. Incorporating green infrastructure that contributes to improved drainage, air quality and the creation of green links through the Morden Regeneration Zone and the Wider Morden Town Centre Area connecting to its surrounding open spaces.

• g. Supporting an appropriate mix of retail, office, community and leisure uses, including night time uses, mainly on the ground floors within the Morden Regeneration Zone and the Wider Morden Town Centre Area, which provide an appropriate level of active frontage where they will and do not have an undue impact on neighbouring amenity;

It is not considered necessary to stipulate that the non-residential uses are mainly on the ground floors – this could restrict the potential for innovative development, which is particularly pertinent given town centre will need to continue to evolve and adapt to weather changing consumer demands and the shifting function of a town centre. The point about ground floor is also made in the site allocation Mo4. If the reference in both policies is retained then this policy and the site allocation should be aligned.

• h. Investigating the feasibility of decentralised energy and district heating which takes account of opportunities within the Morden Regeneration Zone, the Wider Morden Town Centre Area and potentially the wider Morden neighbourhoods. Suitable futureproofing measures should be implemented where appropriate.

• 3.3.6. In 2009 the ‘moreMorden’ vision was endorsed by the Council following the first offer numerous subsequent rounds of public consultation. The aim of this document was to support Morden in becoming a more sustainable town centre, including an emphasis on Morden as an important transport node and supporting a renewed sense of civic pride. regenerated town centre vision is well established, starting with the council adoption of the vision in 2009, and then being This aim has been captured in Local Plan documents thereafter.

• 3.3.11. The SDF will also inform the procurement of for a development partner who will help the council and TfL deliver the redevelopment of Morden town centre. in which Those bidding to be the development partner bidders will need to demonstrate that they are fully committed to delivering the vision, objectives, and principles set out in the SDF and bids would be evaluated based on the strength of this commitment and ability to deliver on it. Hawkins Brown were also required to test the development capacity of various sites within Morden town centre but this aspect of the work is has not been published as it is commercially sensitive and may influence the procurement process.

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• 3.3.13. One of the aims of this Local Plan is to improve the experience for the current and future users of Morden, making it a destination and not simply a thoroughfare. This will be facilitated by improving the quantity, quality and mix of housing offer through intensification of residential development at the heart of Morden, alongside the delivery of a range of associated improvements to the public realm, transport and provision of town centre uses including retail, leisure, restaurants/cafes, offices and other employment uses. retail services.

3.3.14. ….This will also have a significant effect on the types of shops and businesses that will be attracted to the area and is important in enhancing the vibrancy, vitality and economic success of the town centre – helping it to rejuvenate in a sustainable manner that is robust enough to deal with future change.

Town centre are continuing to evolve and are not just about retail provision anymore. This must be recognised in relevant policies throughout the Local Plan, including this policy.

• 3.3.19. As the council and TfL both own a significant portion of land within the Morden town centre, they both have a major role to play in enabling and delivering change within the town centre, particularly within the Morden Regeneration Zone. There are however also multiple other land ownership interests within the Morden Regeneration Zone and a land assembly strategy will be required to ensure that the site can be developed in a comprehensive manner, to avoid fragmented development and suboptimal densities in this highly accessible location.

• 3.3.22. TfL has identified some of their land in Morden their land around Morden underground station as one of their major potential development opportunity sites in London, recognising the benefits that such a development can bring through improvements to the existing transport infrastructure, to help meet the Mayor’s Healthy Streets Approach.

• Suggest paragraph 3.3.25 is moved in front of current paragraph 3.3.23

• 3.3.33. The introduction of higher density development within in the Wider Morden Town Centre Area, and in particular that within the Morden Regeneration Zone, will help to meet the need for additional and mixed housing in the area, and will promote a more balanced and cohesive community. The additional population within the town centre will make existing businesses and services more viable and help sustain more facilities in the future, including the potential to develop a night time economy.

• Suggest paragraph 3.3.45 is moved to before 3.3.41.

• 3.3.55. … The partnership between the council and TfL (since 2015) has strengthened the potential for Morden to be developed comprehensively.

Policy Mo4 – Morden Regeneration Zone Morden Station Offices and Retail Units, Morden Station Surface Car Park and Sainsbury’s (Peel House) Car Park each benefit from existing site allocations within the 2014 Local Plan. TfL support the inclusion of the three existing site allocations and the Underground Station as a single allocation. This will enable the consideration of the regeneration of the site as part of a

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wider comprehensive masterplanning exercise to provide a range of uses including residential, retail and community uses.

It is suggested that the site allocation proposed uses include leisure and that reference is also made to restaurant/café type uses.

The London Underground operational assets will need to be safeguarded, with scope for the consolidation of uses to allow a more efficient use of the site.

With regard to the criteria outlined in the Regeneration Zone site vision see the comments raised in the Policy N3.3 section and align as appropriate.

York Close Car Park York Close Car Park benefits from an existing site allocation within the 2014 Local Plan, and the proposed site allocation in the Local Plan for residential use is supported, as is the inclusion of the site as part of the Wider Morden Town Centre Area.

The following amendments are suggested to the policy wording:

Site allocation: Parking and residential of or solely residential, if not needed for parking

Design and accessibility guidance: Development proposals will need to be sensitive to the residential amenity of the existing neighbouring dwellings and the occupiers of any new dwellings (as an in line with the Agent of Change principles set out in the London Plan), not harm the viability and growth of the adjacent train depot and must incorporate suitable mitigation measures to address the critical drainage issues.

Morden Depot This site comprises a 5.64ha parcel of land, currently in use as a London Underground operational facility along with an ancillary parcel of land to the north (see accompanying plan). The site is included in the Wider Morden Town centre Area and represents a large piece of brownfield land in an accessible location. TfL have identified that in the future there may be potential to reconfigure the site in a more efficient manner to enable redevelopment of parts of the site. Should this be feasible, the site could have the potential to deliver a substantial amount of development, subject to the safeguarding of the operational facilities. This is something that will continue to be explored, however it is not considered this would be a shorter term aspiration. As such, its inclusion in the Wider Morden Town centre Area, and not as part of a site allocation, is supported.

Policy N3.5 – South Wimbledon The general intent of this policy is supported, in particular the proposal for a new Local Centre at the heart of the South Wimbledon, focussed around the underground station and junction and the reference to support for suitable redevelopment of the South Wimbledon Station. It is noted that the policy entry states that public space and a secondary public entrance to the underground station is encouraged, which is considered appropriate.

Reference should also be made to the potential for residential development above the shops and station to enable efficient use of a highly sustainable location, in line with policies in the publication London Plan and NPPF.

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South Wimbledon Station and 1-7 Morden Road This site comprises the Grade II Listed station and adjacent commercial premises (see accompanying plan). The site is available and developable for residential or mixed use development, subject to feasibility studies (taking into account the listed nature of the station). A site allocation should be considered for this site.

Concluding Remarks We trust that we have provided sufficient information for the Council to be able to consider our representation in respect of the Local Plan consultation and would appreciate if you could confirm receipt of this letter. Should you have any queries or require any additional information, please do not hesitate to get in touch.

Yours sincerely

Rosie Sterry

Planning Manager, Commercial Development Email: [email protected]

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7 0 17 Transport for London Date : Dec 2015 TfL Operational Property N Initial : REM Commercial Development MEL010 Windsor House File : PAR 42-50 Victoria Street SW1H 0TL A3 Portrait Scale : 1/2000 at A3

5 OSE 1 DOEL CL Court Marsh Marsh

15.0m

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Ps Ps

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5 0

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0 1 1 4

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File : PAR File

Initial : REM : Initial Date : Mar 2016 : Mar Date 1 s Scale : 1/1250 at A3 1/1250 : Scale

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May May

8 1

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1 to 66 to 1 66 t

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14.1m

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0 1 to 66

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St John's 2 Works Parish Hall

206 N O

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Ryder House

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214 214 1

33 to 64

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230a 230a Gilbert 2

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3 4

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4 A

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4 3 D 1 Church Church

1 2 A 8

7 O

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2 U

Rising Bollard Rising

1 6

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14.4m

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SW1H 0TL

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Windsor House

2 3

4 9

42-50 Victoria Street Victoria 42-50

3 4 TfL Operational Property TfL Operational

Commercial Development Commercial

4 9

4 4 2 t Transport for London Transport for o

r 2

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4 E 7 8 36 3 14.5m 32 5 NUE 1 AVE NE

SBA

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Burleigh Lodge 3 5

22 14.4m

2 3

Mayor ofMayor London 14.4m