Development, Enterprise and Environment

Emma Williamson Our ref: LDF14/LDD16/CG01 Assistant Director, Planning Date: 16 March 2018 Haringey Council River Park House 225 High Road London N22 8HQ

By email : [email protected]

Dear Mrs Williamson

Planning and Compulsory Purchase Act 2004 (as amended); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) Regulations 2012

Re: Consultation on Wood Green Area Action Plan - further preferred option stage (February 2018)

Thank you for consulting the Mayor of London on this further Regulation 18 consultation for the Wood Green Area Action Plan (AAP). As you are aware, all Development Plan Documents (DPDs) must to be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. The Mayor has delegated authority to me to respond and his representations are set out below. These representations include comments from (TfL), which I support and are included in this letter. More detailed comments from TfL are also attached as Annex 1.

The London Plan The Mayor published his draft new London Plan for consultation on 1st December 2017. It is anticipated the Examination in Public of the London Plan will take place in the Autumn 2018 with publication in Autumn 2019. Haringey has recently published its Local Plan, which this Wood Green AAP must be in conformity with, however it is expected to also align with the draft new London Plan as the London Plan policies gain more weight, as it moves towards publication. Once published, the London Plan will form part of Haringey’s Development Plan. In addition, the draft new London Plan is a material consideration in planning decisions.

Wood Green Area Action Plan

Strategic context

My previous letter (02 May 2017) set out the strategic context of Wood Green in term of the current London Plan. As stated above, since my previous response the draft new London Plan has been published. The draft new London Plan increases Haringey’s housing target from 15,019 homes over 10 years to 19,580 homes over 10 years. Of this, the capacity for 4,277 homes has been identified on large sites in Wood Green through the London SHLAA 2017. Draft new London Plan policy H2 Small sites sets Haringey a target of 6,260 homes from small sites over 10 years.

City Hall, London, SE1 2AA ◆ london.gov.uk ◆ 020 7983 4000

The draft new London Plan (policy SD1) proposes to designate Wood Green/Haringey Heartlands as an Opportunity Area with the capacity for 4,500 homes and 2,500 jobs (Figure 2.6), an increase from the minimum of 1,000 new homes and 2,000 new jobs identified in the current London Plan (Table A1.2).

Wood Green continues to be classified by the draft new London Plan as a metropolitan town centre, in recognition of its catchment and role as a centre for retail, employment, service and leisure functions, as well as its good public transport accessibility. Table A1.1 of the draft new London Plan recognises the town centre as having medium potential for commercial growth, including for retail, leisure or office floorspace, with the physical and public transport capacity to accommodate it. The town centre is also identified as having high potential for residential growth. It is identified as an area of regional or sub-regional night time function.

Wood Green town centre remains a strategic area for regeneration where issues of spatial inequality should be tackled along with as its environmental, economic and social barriers in line with draft London Plan policy SD10 Strategic and local regeneration.

The Secretary of State is currently considering two options for future services in the Wood Green and Haringey Heartlands area. These comprise: (1) an option for stations at both Turnpike Lane and ; or, (2) an option for one station at Wood Green. Once the Secretary of State has made his decision on Crossrail 2 alignment there will be public consultation on the preferred route. The increased connectivity and enhanced transport capacity that would be provided by Crossrail 2 offers significant opportunities for further growth and sustainable town centre intensification in line with draft new London Plan policies SD1.

Scope of the preferred option

This draft of the Wood Green AAP builds on the previous preferred option version for the growth and development of Wood Green over the next 10 years, taking into account the consultation responses. It is noted that the timeframe for delivery has been rolled forward and that some sites identified in the AAP are not anticipated to be delivered until at least 2028, which is beyond Haringey’s Local Plan period. The delivery period is within the London Plan period and contributes to identifying housing capacity for at least the next 10 years. However, Haringey should clarify the dates of this AAP.

The revised densities now take into account Crossrail 2 has not been confirmed and therefore the AAP cannot consider the improved accessibility and investor confidence that would flow from the significant transport infrastructure. In this regard, the projected number of new homes has been reduced from 7,700 homes to 6,478. The employment floorspace capacity has reduced from 102,000sqm to 95,000sqm and the retail capacity from 71,760sqm to 55,000sqm. A range of economic, environmental and place-making measures intended to revitalise Wood Green town centre are still proposed. The proposed spatial strategy and the draft policies to deliver this growth within the emerging AAP area, are considered in more detail below.

Spatial strategy and overall capacity

The draft Wood Green APP promotes the intensification and regeneration of the metropolitan town centre, and seeks to align growth with the potential future provision of transport capacity and other essential physical and social infrastructure. This is strongly supported in accordance with draft London Plan policies SD1, SD6, SD10 and T3. The draft AAP represents a significant degree of

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intensification and change (even with the reduce capacity from the 2017 draft AAP) for this outer London town centre and makes a contribution towards Haringey finding additional capacity to meet its new housing target. The focused growth in Wood green is in line with the principles of sustainable development and supports the reclassification of Wood Green as an employment led Opportunity Area in the draft new London Plan.

The Mayor’s previous letter welcomed the potential capacity identified in the draft AAP – 102,000sqm employment floorspace, 71,800sqm retail floorspace and 7,700 additional units. You will note that the draft new London Plan no longer includes the density matrix and promotes a design led approach to ensuring the efficient use of land and optimising residential density (D1, D2, D6). The Mayor would encourage Haringey to implement the measures set out in draft London Plan D2 Delivering good design to evaluate the capacity of the AAP area. In this regard, the Mayor supports draft policy WG2 (2) which seeks a design led approach and supports higher densities, where appropriate. He also welcomes the removal of site allocation 9 which was included in the previous draft which proposed the comprehensive redevelopment of several Victorian/ Edwardian residential terraces (at Mayes Road and Caxton Road).

Once the full potential of the area has been determined, consideration should be given to the capacity of the transport network and development phased in line with any required increased capacity. See the transport comments below, and attached as Annex 1.

It is also noted that most allocation sites propose mixed use development. The Council may consider whether it would be more appropriate to cluster uses in order to foster innovation and collaboration between businesses and to facilitate servicing. In addition, Grade A offices are most likely to be delivered closer to public transport nodes.

Land ownership and development potential

Along with various private freeholders, the Council is a major landowner in the AAP area. As stated in his previous letter the Mayor welcomes the consideration given to the distribution of uses, social infrastructure and public space relative to land ownership patterns in order to find a configuration of development that, whilst always ensuring site viability, would optimise the balance of public/private benefits and burdens in order to deliver the strategy. The Council should note the increased focus on housing delivery set out both in the draft new London Plan and draft national policy and should optimise the potential of its sites to facilitate housing delivery that supports Wood Green as a metropolitan centre.

Where an estate is to be regenerated the Council should follow the Mayor’s draft guidance ‘Proposed new funding condition to require resident ballots in estate regeneration’ consultation paper at: https://www.london.gov.uk/sites/default/files/consultation-on-a-new-funding- condition-requiring-resident-ballots-in-estate-regeneration-schemes.pdf This document proposes that the GLA applies a new condition in its Affordable Housing Capital Funding Guide requiring evidence of a positive vote in a resident ballot before new allocations of affordable housing grant are made to estate regeneration projects that involve demolition of existing homes.

Housing

As stated above, the draft new London Plan increases Haringey’s housing target to 19,580 homes. The revised draft AAP plans for the delivery of 6,400 new homes in Wood Green/Haringey Heartlands (down from the 7,700 in the previous version of the AAP) which is 1,900 homes above the housing potential identified in the draft London Plan for the Opportunity Area. As stated in his

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previous letter when more housing was proposed, this level of housing supply is strongly supported in accordance with London Plan Policy 3.3 and we would support the borough in applying the design led approach set out in draft London Plan policy D2 to identify the potential for additional housing capacity – noting that delivery may have to be phased in line with the delivery of increased transport capacity – so that this accessible part of the borough can make its fullest contribution to meeting Haringey’s housing target.

As stated above, draft new London Plan policy H2 Small sites sets Haringey a target of 6,260 homes from small sites over 10 years. Small sites are those that can deliver between one to 25 homes and should particularly come forward as infill development on vacant or underused sites and in the form of increased density within PTALs 3-6 or within 800m of a Tube station, rail station or town centre boundary. The AAP should reflect the potential for additional housing capacity that could come forward on small sites.

More generally, as stated previously, the Mayor has no objection to the Council’s proposed portfolio approach to meeting objectives for family housing and affordable tenure split across a range of sites. However, the AAP should note the Mayor’s 50% strategic affordable target and the threshold approach with a minimum target of 35%, and 50% for public sector land, without grant. Given that the AAP area contains industrial land, the AAP should also note the 50% target for industrial land, deemed acceptable to be released, set out in draft London Plan policy H6.

The Mayor welcomes the reference to the Council’s Rehousing and payment policy, particularly in relation to the proposed redevelopment of housing estates within Wood Green. In accordance with Policy H10 Redevelopment of existing housing and estate regeneration of the new draft London Plan, the AAP should reference and take account of the principles set out in the Mayor’s Good Practice Guide.

Employment

The draft AAP seeks to deliver 95,000sqm of new B Class employment space (4,000 new jobs) as part of a drive to achieve a local economy of critical mass within Wood Green’s commercial core and support Wood Green’s continued classification as a metropolitan centre. This is expected to deliver approximately 4,000 new jobs. This is well in excess of the draft new London Plan target for the proposed Opportunity Area of 2,000 but is in line with the aims of the proposed employment led Opportunity Area. The proposal to deliver grade A office space to support Wood Green’s Metropolitan status and improve the density and quality of jobs is supported.

It is also proposed to transform the Heartlands area into a mixed-use area including a core of civic office space and workshop space. This area contains a significant amount of creative workspace and some industrial uses. Due to the much greater release of industrial land than that stipulated in the London Plan monitoring benchmarks, the draft new London Plan promotes the intensification of industrial activities (draft Policy E4) and where appropriate (in line with emerging policy E7), co- location with residential development.

In addition, draft London Plan policy E2 seeks the provision and where appropriate the protection of low-cost business space to meet the needs of micro, small and medium-sized enterprises and draft policy E3 seeks the provision of affordable workspace in certain circumstances.

The Mayor is confident that the draft AAP shares the ambition of the draft new London Plan to support a variety of businesses and that it will deliver additional industrial and workshop capacity in the form of B1c/B2/B8 or SG industrial floorspace. Haringey should ensure that existing

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businesses, especially industrial and workspace uses are consulted and there is a strategy in place to re-locate this businesses within the area.

As stated above, the borough should consider the benefits of clustering employment uses to support innovation and collaboration between businesses, ensure appropriate design solutions and to maximise the potential for delivery.

Retail

The draft AAP proposes 55,000sqm of retail floorspace, however the evidence suggests there is only a need for 20,000sqm of retail floorspace. The Mayor is supportive of the borough’s overall ambitions for Wood Green and recognises to improve its competitiveness additional retail provision is needed. However, Haringey should set out a strategy for the delivery of the proposed retail floorspace including phasing and alternative land uses should the retail capacity not be required/come forward.

Tall buildings and views

In line with the Council’s Local Plan, the draft AAP recognises Wood Green as suitable for tall buildings. The Mayor welcomes the approach in the draft AAP to promote a case by case design- led approach, having regard to the relevant London Plan and Local Plan urban design policies; a Tall Buildings SPD (which the Council is currently developing); and the opportunities and constraints presented by local viewing corridors that oversail the town centre. With respect to the latter, it is noted that the Council has opened up a new local view to Alexander Palace from High Road (as part of the comprehensive remodelling of the town centre). As stated in the previous letter, the Council is encouraged to present an illustrative massing model within the next draft to provide a tangible vision for the local community.

Metropolitan Open Land

The AAP area is principally urban town centre, however, the boundary crosses the Great Northern Railway Line to include Filter Beds (a partially locally listed water treatment works on Metropolitan Open Land), adjacent to Alexandra Park. The Mayor places great importance on protecting MoL from inappropriate development. AAP site allocation 28 suggests residential- enabled consolidation of waste water infrastructure, and the delivery of a new pedestrian/cycle connection between Wood Green town centre and Alexandra Palace. Whilst the site allocation development guidelines emphasise that development of this site should not have a greater affect on openness, the suggestion of residential use at the site (up to 304 units) leads to conflict with London Plan Policy 7.17 and draft London Plan policy G3.

Notwithstanding this, it is noted that the site has, in part, been previously developed in connection with the existing waterworks use. It is also acknowledged that improved access to open space at Alexandra Park would be of huge benefit to Wood Green in view of the intensification proposed within the town centre.

Transport

The draft London Plan identifies an indicative capacity of 4,500 homes for the Wood Green Opportunity Area, which the draft AAP encouragingly and correctly seeks to exceed. Notwithstanding this, Para 2.1.11 of the draft new London Plan is clear that “where development proposals are emerging and transport investment is not yet fully secured, delivery of the long term

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capacity will need to be phased in a way that maximises the benefits from major infrastructure and services investment, whilst avoiding any unacceptable effects on existing infrastructure before the new infrastructure is available”.

The borough should clarify how the housing and employment targets will affect the capacity of the existing transport network and potential future transport improvements. The planned delivery and phasing of the AAP must ensure there is no unacceptable affects on the existing transport network and that longer term development opportunities reflect the opportunities from planned future investment. The transport study will therefore be a key element of the evidence base which needs to be completed before the AAP is finalised.

Any transport study will need to utilise TfL’s strategic models and should consider the ability of the existing transport network to support the proposed level of development as well as what the dependency on future investment may be (including buses, pic line upgrade and CR2). TfL will support LB Haringey in assessing the transport affects and would welcome an opportunity to work jointly with LB Haringey in scoping and developing a strategy for how transport can support the ambitious growth aspirations set out in the AAP.

Further transport detailed comments are provided in Appendix 1 to this letter.

Conclusion

The scale of ambition of this plan is strongly supported in strategic planning terms and the proposed housing and employment outputs are in keeping with Wood Green being reclassified as an employment led Opportunity Area within the draft new London Plan. In general, the draft AAP has progressed well since the previous stage of consultation, however, the Council should ensure that the matters discussed above are addressed by the next consultation draft.

The Mayor will issue his formal opinion on general conformity when requested at the Pre- Submission consultation stage. In the meantime, I look forward to the continued joint engagement of the development of this AAP. Please contact Celeste Giusti, 020 7983 4811 / [email protected] to discuss any of these representations in more detail, and/or to arrange a meeting.

Yours sincerely,

Juliemma McLoughlin Assistant Director – Planning cc Joanne McCartney, London Assembly Constituency Member Nicky Gavron, Chair of London Assembly Planning Committee National Planning Casework Unit, DCLG Lucinda Turner, TfL

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Annex 1 TfL Wood Green AAP Response

Key Points • The growth assumptions in the AAP are much higher than LBH’s Site Allocation SPD and draft London Plan and only slightly lower than the 2017 AAP which assumed Crossrail 2 would be serving Wood Green; LB Haringey need to demonstrate that this level of growth can be supported with the assumed transport provision. • This document refers to a ‘Transport Study’ in several places, TfL request further information on what this entails and would like to work jointly in developing a strategy for how transport can support growth in Wood Green • TfL note the predication that this AAP is based on no Crossrail 2 in the Wood Green area. However, whilst a decision on how the Government wishes TfL to take forward the Crossrail 2 project, provision for sites necessary to deliver Crossrail 2 (as consulted on in 2015 and available online at Crossrail2.co.uk) and the ability to deliver the necessary station and works at Wood Green should be reflected in this AAP • The AAP should make greater reference to Healthy Streets as this is a priority for the draft London Plan in terms of shaping all planning decisions and the draft Mayors Transport Strategy • Bus contributions should be seen as a s106 priority for development in the Wood Green area and especially from new developments to the west of the High Road. This is especially important where multiple smaller sites are being developed, a consolidated approach would be useful to ensure the cumulative affect of all sites is considered and sufficient contribution to bus network development to address the lack of access to the bus network within some parts of this area.

Crossrail 2 The Secretary of State is considering two options for future Crossrail 2 services in the Wood Green area. These comprise: (1) an option for stations at both Turnpike Lane and Alexandra Palace; or, (2) an option for one station at Wood Green. The Secretary of State’s decision on Crossrail 2 alignment is expected later in 2018, after which there will be a public consultation on the preferred route. The increased connectivity and enhanced transport capacity provide by Crossrail 2 offers significant opportunities for growth, regeneration and town centre intensification.

This draft of the Wood Green Area Action Plan (AAP) sets out Haringey Council’s preferred option for the future growth and development of Wood Green and replaces a 2017 consultation of a preferred options. The 2017 AAP consultation focussed on option 2 of the above Crossrail 2 configurations and the growth figures were based on Crossrail 2 serving Wood Green.

The updated 2018 ‘Preferred Option’ AAP recognises that a decision on Crossrail 2 is still to be made by the Secretary of State and that while the scheme is not committed or funded the plan can not take into account density increases supported by the improved transport considerations. This draft of the AAP still references that a future Crossrail 2 route would serve Wood Green station under option 2 above which is supported by GLA as it would provide the most significant quantum of housing and economic growth for the Wood Green area. However, the AAP should make clear that there are alternative route options and if the Wood Green alignment is not selected by the Secretary of State as the preferred route

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the AAP would require an update. In addition, we would recommend an early review of AAP when Crossrail 2 becomes funded and committed to ensure development potential unlocked by Crossrail 2 is considered. It should also be noted that whilst a decision on how the Government wishes TfL to take forward the Crossrail 2 project, provision for sites necessary to deliver Crossrail 2 (as consulted on in 2015 and available online at Crossrail2.co.uk) and the ability to deliver the necessary station and works at Wood Green should be reflected in this AAP. Further details on specific sites are referenced below. TfL welcomes the removal of reference to an entrance of a Crossrail 2 station at the library site as outlined in the 2017 Preferred Options consultation.

We would like to continue to work with the council to best maximise the regeneration and development opportunities from Crossrail 2 in the Wood Green area.

Development Capacity Assumptions

The LB Haringey adopted Site Allocations DPD identified the potential for 4,300 net additional residential units and 64,000m2 of employment/town centre floorspace in Wood Green. The draft London Plan identifies Wood Green/Haringey Heartlands as a new Opportunity Area with the potential for 4,500 net additional resident units and 2,500 additional jobs.

In 2017, the Preferred Option AAP consultation identified potential for 7,700 residential units and 170,000m2 of employment/town centre floorspace at least in part based on development uplift as a result of Crossrail 2. This 2018 version of the AAP identifies potential for 6,500 residential units and 150,000m2 of employment/town centre floorspace.

At present there is no commitment to funding Crossrail 2, and so this updated 2018 version is predicated without Crossrail 2. The AAP states that density increases based on Crossrail 2 are not included in the document. However, this document has a much higher level of development compared to the draft London Plan and Site Allocations DPD. While TfL notes the overall quantum of development (especially residential) is lower in this document the 2017 consultation much of this reduction is from converting some residential to employment uses and a number of sites have also been removed from this document (e.g. Caxton Road). We would have expected a bigger difference between the densities and quantum of development achieved with and without Crossrail 2. There is also the question of viability and whether there will be sufficient investor confidence without Crossrail 2; a point alluded to in paragraph 6.7.

Evidence needs to be provided that planned improvements to the transport network are sufficient to accommodate the level of growth set out within this document. Our concern is that the AAP could enable too much development ahead of the opening of Crossrail 2 causing increased pressures on the transport network and undermining the economic and wider regeneration/development case for Crossrail 2 and particularly the New Southgate branch.

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Transport Study

The levels of growth within this document would be occurring without the introduction of Crossrail 2 and the transformational affect on transport capacity and connectivity it provides. Therefore, the existing transport network would have to support this level of growth. We welcome reference to a Transport Study however there is limited detail on its content.

The AAP refers to a transport study which has been commissioned which identifies that the transport affect from new development will not be significant. It is not clear whether this study has been commissioned or completed. TfL City Planning has not been consulted upon on the content of this piece of work, nor been asked to use our strategic transport models and we would like to meet with the council to discuss the scope at the earliest opportunity.

Our reading of the AAP implies that the transport study essentially says that there would be no traffic re- assignment due to the proposed development. This would seem surprising. We’d recommend that the consultants engage with TfL City Planning and utilise TfL’s suite of strategic models to assess the wider affects of the proposed development levels.

TfL is happy to be engaged on the early details of proposals to specific junctions and can provide early feasibility / design / scheme assessment advice.

Further, while the AAP references increased capacity on the , the scale of development proposed in the Wood Green AAP will increase demand substantially on the Piccadilly line and at both Wood Green and Turnpike Lane stations. TfL would therefore require an assessment of the increased demand and affect on crowding at Wood Green/Turnpike Lane station, the Piccadilly line (including on the route further into central London) and particularly from interchange onto the Victoria line.

Healthy Streets

The AAP should make greater reference to Healthy Streets as this is a priority for the draft London Plan in terms of shaping all planning decisions. Many of the concepts within the APP do align with Healthy Streets concepts such as improving urban realm to provide more space for walking and cycling, better spaces where people can interact and planning new development so people can walk or cycle to their destination, or use public transport including bus for longer journeys. However, linking these concepts to Healthy Streets would provide a stronger link to policy in the new draft London Plan and Mayors Transport Strategy.

Bus s106

The bus network forms a critical part of the Mayor’s Transport Strategy and TfL’s Healthy Streets approach, and bus is an extremely important mode of transport for accessing Wood Green so a future bus network supporting new development should be a core component of the AAP.

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Bus contributions should be seen as a s106 priority for development in the Wood Green area and especially from new developments to the west of the High Road. This is especially important where multiple smaller sites are being developed, a consolidated approach would be useful to ensure the cumulative affect of all sites is considered and sufficient contribution to bus network development to address the lack of access to the bus network within some parts of this area.

Detailed Comments

The SWOT for the AAP (p31): Recommend removal of Crossrail 2 as a threat, this appears to be in place from the 2017 AAP which assumed Crossrail 2 would be in place. This version is predicated without Crossrail 2 so should appear only as an opportunity and not a threat. Opportunity for Crossrail should state “additional development and regeneration potential from the proposed Crossrail 2 line”

SWOT for North sub-area and Central area should both refer to the additional development and regeneration opportunities from Crossrail 2 and as above not refer to it as a threat.

3.31 The emission levels for buses and HGVs should be separated.

Reference should be made that the area will benefit from the ‘High Road to Green Lanes’ Low Emission Bus Zone which will see any TfL scheduled bus travelling along the corridor meet Euro VI emissions. Additionally, a number of bus routes that operate along the corridor enters the Ultra-Low Emission Zone. There are also various other air quality initiatives we are delivering to reduce tailpipe emissions from the TfL bus fleet. TfL would welcome working with the council on measures to further reduce emissions. Also applies to 4.38 (p52)

4.33 Should reference the two possible route alignment options through the Wood Green AAP area, recommended text:

“TfL and Network Rail are leading on the development of the Crossrail 2 rail line. The 2015 consultation outlined two route options serving the Wood Green area, one with stations at both Turnpike Lane and Alexandra Palace with the option having a single station at Wood Green. The Secretary of State has not announced which option will be taken forward as the preferred scheme though currently the safeguarding is for the route via Turnpike Lane and Alexandra Palace. The previous version of the AAP document was predicated on the introduction of a single Crossrail station at Wood Green underground station, with access into the Central Wood Green Area, which is the Council’s preferred solution. At present there is no commitment to funding Crossrail 2, and so this version is predicated without this improvement.”

Note, it may be beneficial to include this text at the beginning of the AAP as well, such as in section 3.27

4.36 Wood Green and Turnpike Lane need to be referred to separately. Wood Green does not have a bus station. Passengers board and alight at stops on the High Road, Lordship Lane and Station Road, in the vicinity of Wood Green Tube Station. Buses stand on the highway on the north side of Buller Road and on the east side (offside) of Redvers Road, to the north and the south of the Buller Road

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junction. Turnpike Lane does have a bus station, which is an “off highway” facility, adjacent to and above Turnpike Lane Tube Station, providing passenger interchange and bus standing.

TfL is in discussion with LB Haringey about options for expanding the local bus network to serve the Haringey Heartlands development. As noted in TfL’s previous response, the word ‘extending’ should be used in place of ‘spreading’ which suggests dilution – this may not be the case.

It appears figure 5.1 has not been updated from the previous AAP as it includes the now removed Caxton Road properties and refers to a Crossrail 2 entrance at the library site which has been removed from the rest of the document. Figure 5.1 should state “Potential Crossrail 2 station entrance”

Figure 5.1 (page 57) & Figure 5.5 (page 61) – These show public realm improvements for Coburg Road. As noted above, TfL is in discussion with the borough about options for improving bus access to Haringey Heartlands. Exactly how bus improvements would be provided has yet to be determined and may include a route via Coburg Road. As such, it is important at this stage that reference to any public realm improvements does not exclude the option for a bus service running via Coburg Road.

Figure 5.2 and 5.3 should include the “Potential Crossrail 2 station entrance” at the Vue cinema site. However, we’d request removal of the Crossrail branding on the artists impression alongside Figure 5.3 as this based on the 2017 AAP.

6.12 The only transport infrastructure improvements outlined are improved cycle links. Additional infrastructure is likely to be required for the level of growth outlined in the AAP.

6.13 Wood Green North. There are two references to Wood Green Bus Garage on page 66 (Also Figure 5.1 page 57 & Figure 5.2 page 58). Wood Green Bus Garage is an important facility for running buses and is owned by Arriva, so any reference to redevelopment of it would also need to be commented upon by the bus company. Any redevelopment of the bus station should have comparable facilities plus capacity to support an expanded network should growth be considered. Any location of for redevelopment, collocated or relocated facility should not add additional bus mileage which could increase road congestion and add operational costs.

Also under point 7 (Wood Green North), the reference to bus garage and bus standing facilities suggest that the two are the same. They are not. The bus stand in the bus garage is a private stand with 8 spaces, which may be available between 07:30 to 18:00 by arrangement for terminating/curtailing services run by Arriva only. This does not form part of the stand provision for Wood Green, which must be in independent locations for competitive tendering, currently provided at Buller Road and Redvers Road.

Public realm 6.15: Redevelopment along the High Road has to enable the provision of an attractive walking and cycling environment (healthy street). This means where appropriate setting back development (on the mall sites in particular) to allow cycle lanes, wider footway space planting, seating, etc to be installed

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Figure 7.13: We request removal of the Crossrail branding from the artistic impression as this was produced for and based on the 2017 AAP.

7.63 See comment RE: urban courtyard atop a decked Wood Green bus garage

Policy WG11 Transport (and supporting text)

There is limited reference to what is proposed, particularly around mode shift and active travel. There is limited reference to reduce the need to drive (or actively discouraging driving) and getting people to walk, cycle and take public transport.

TfL welcomes the concept of improved pedestrian routes but there is a lack of detail of how they will be designed and what will distinguish from normal streets. Are they traffic-free routes, or access-only, or does it mean specific public realm improvements, or creating new connections where they didn’t previously exist?

7.81 The local bus network will remain under review. We will actively participate in the evaluation of individual planning applications as they are brought forward to determine their likely affect on the network. As discussed with Haringey officers, mitigating the cumulative affect of bus demand from development sites, especially to the west of the High Road, should be a priority for the Wood Green AAP and future s106 contributions. This paragraph also specifies the possible diversion of a route via Mary Neuner Rd, Clarendon Rd and Western Rd. This is currently only one possible outcome of an extension of the network into Haringey Heartlands. A more likely option is the extension of an existing route to terminate at or close to the site. The wording should be changed to “this may include an extension or diversion of a route to serve Haringey Heartlands”.

Figure 7.18 – Again this shows Coburg Road as a pedestrian-only route when the operation of a bus route via Coburg Road has not been ruled out.

Figure 7.19 doesn’t appear to show any current or future cycling routes.

Figure 7.20 Legend should state “Potential Crossrail 2 station entrance” and for the safeguarding “Crossrail 2 route Autumn 2015 alignment safeguarding*”

* the Secretary of State has not made a decision on which Crossrail 2 alignment in the Wood Green area will be the preferred route, at present only the Crossrail 2 route option via Turnpike Lane and Alexandra Palace is safeguarded. However, during the last consultation an option via Wood Green was consulted upon which included accompanying facts sheets with a station at Wood Green.

We would recommend brief mention of Crossrail 2 in the transport section stating that is not committed but could be delivered within the plan period and would offer a transformational change in capacity and connectivity to central London.

Figure 8.3 needs updating for new site boundaries within The Mall West to exclude Caxton Road

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Wood Green Investment Framework: The AAP should make clear that bus contributions will be a section 106 priority from development to the west of the High Road and elsewhere in the town centre where necessary.

Site Allocations

A number of allocated sites were identified as potential worksites by the 2015 Crossrail consultation material. It may also be beneficial to reference that TfL/Crossrail 2 would own these sites post construction. TfL would therefore welcome further discussions with the Council on their redevelopment in due course.

Sites affected by Crossrail 2 surface interest for worksites: WG SA 2 (Green Ridings House), WG SA 3 (Wood Green bus garage) and WG SA 5 (Vue Cinema) Development Guidelines should mention: “although not safeguarded this location has been identified in the 2015 consultation by Crossrail 2 as an area of surface interest for a worksite and therefore Crossrail 2 could act as a barrier to developing these sites until after construction (2030+).”

WG SA 3

Any proposed redevelopments (or alternative locations) must be discussed with TfL and Arriva. The garage is strategically located for the optimum operation of a number of routes, including high frequency from the garage. Any redevelopment (which might affect the garage) or even removal of the garage will have a significant affect on the bus network, increasing costs and congestion.

Bus stabling/maintenance and standing facilities would need to be provided through any construction works and should be a requirement of site redevelopment.

The size required for future bus station has reduced from 9,520m2 to 8,288m2, this is surprising due to planned in Wood Green Town centre and the wider area. TfL would like to understand further the assumptions behind this.

The timeframe for delivery should therefore remove the 2023-2028 timescale

WG SA 5 Vue Cinema: We welcome reference to a potential Crossrail 2 entrance but the development guidelines should use the same text as WG SA 2 and 3.

We question the requirement to create a significant public space (“plaza”) at this location and to visually separate it from the High Road (by creating a “landscaping perimeter”). The area suffers from a lack of spatial definition and no framed views towards the heart of the retail area, which should be addressed by moving the building line on this site closer to the High Road to reflect the arrangement across the road. The gateway effect could be reinforced by tree planting on both sides of the High Road. The proposed (low level) landscaping screening would create unnecessary visual separation between the passing traffic and pedestrians, which would reduce passive surveillance and would be detrimental to

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the proposed secondary retail uses on ground floor. A significant public space here would compete with the proposed Town Square on the Library site – only about 120m away. The guidelines for the Vue Cinema site should mention instead the requirement to create a comfortable pedestrian environment (including adequate pavement width) and active frontages along the full length of the High Street and Lordship Lane facades.

The 11 stand spaces currently provided at Buller Road and Redvers Road are insufficient for the existing level of bus service terminating in Wood Green, so site requirements should allow for the provision of at least 2 additional stand spaces, to accommodate the existing network, without any allowance for growth.

WG SA 6: MECCA BINGO Include reference to potential use of site for public transport facilities.

Part of the western boundary of this site affects the public stand for 1 bus on the east side (offside) of Redvers Road extending 20m south from Buller Road, so the paragraph about bus standing on page 115 needs to be repeated on page 117. Consideration of a new bus station in this area of Wood Green (20 stand spaces) would enable consolidation of on highway stands to an “off highway” facility and provide opportunities to review the level of service along Wood Green High Road, between Wood Green and Turnpike Lane.

WG SA 9: The Mall West: The proposed site allocation refers to “surrounding properties”, this appears to an erroneous description based on the 2017 AAP and should be removed. Note the map also doesn’t appear to include the community facilities on Caxton Road although the text states these are still included.

WG SA 14: 16-54 Wood Green High Road: The site requirements refer to part of this site being safeguarded for the construction of Crossrail 2. While this is correct there are a large number of other sites which are within the current safeguarding (Turnpike Lane/Alexandra Palace alignment) which do not reference Crossrail 2. For the purposes of consistency we recommend you reference other sites that are within the current safeguarding directions for Crossrail 2.

WG SA 17: Turnpike Lane Station site: The site requirements need to include re-provision of the bus station and the Development Guidelines should specifically refer to consultation with TfL about how this is achieved. The 13 stand spaces currently provided are insufficient for the existing level of service terminating at Turnpike Lane, so site requirements should allow for the provision of at least 4 additional stand spaces, to accommodate the existing network, without any allowance for growth. Also under point 6 (Development Guidelines on page 143), there is the suggestion of a “cycling connection” through the bus station. This should be removed as it would create safety and operational issues.

WG SA 23 Clarendon Road site – pages 156 & 157. WG SA 27: Clarendon Road South site – pages 164 & 165. This Site Requirements section stipulates that provision for a bus route and stop will be required on Mary Neuner Way (sic). As stated above, this has not been agreed. This could be re-worded to state that passive provision is required to future-proof the road in case a bus service operates via Mary Neuner Road in future.

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General: TfL would welcome discussions with the Council on which, if any of the site allocations could have an increased development quantum once Crossrail 2 is confirmed. This would help to more clearly quantify the benefits of Crossrail 2in this area and to assist TfL with the next iteration of the business case. TfL would welcome the opportunity to work closely with the Council as the AAP, and more detailed site specific proposals are progressed.

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