planning report D&P/3731/01 27 June 2016 80-86 Bushey Road, in the Borough of planning application no. 16/P1317

Strategic planning application stage 1 referral Town & Country Planning Act 1990 (as amended); Authority Acts 1999 and 2007; Town & Country Planning () Order 2008.

The proposal Demolition of existing retail, office and industrial buildings and erection of a retail park (Class A1) with complementary cafe/restaurant units (Class A3) together with access and servicing arrangements, car parking, landscaping and associated works.

The applicant The applicants are Aviva Investors, Friends life Limited and Shearer Property Group and the agent is Quod. The architect is Chapman Taylor.

Strategic issues summary Principle of development: The proposal is a departure from the development plan due to the allocation and designation of the site, including as a locally significant industrial site and needs to be more fully justified in policy and employment terms (paras 21-22). Retail: Further verification of the findings of the sequential test, impact on vitality and viability of town centres and investment in town centres is needed to test the scheme’s impact on the retail hierarchy. Further discussions between Merton Council and Kingston Council are required (paras 23-33). Urban design and heritage: Concerns with the layout of the development and inward looking design. The demolition and relocation of the locally listed building is not sufficiently justified and further consideration should be given to its retention and restoration into the scheme (paras 34- 39). Transport: Further work is needed on the trip generation and modelling in order to establish requirements for any mitigation towards the highway and public transport networks. Information regarding Blue Badge parking spaces, car park management strategy, cycle and pedestrian routes and facilities is required, together with conditions and planning obligations (paras 50-73). Recommendation That Merton Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 78 of this report but that the possible remedies set out in that paragraph could address these deficiencies.

page 1 Context

1 On 26 April 2016 the Mayor of London received documents from Merton Council notifying him of a planning application of potential strategic importance to develop the above site for the above uses. Under the provisions of The Town & Country Planning (Mayor of London) Order 2008 the Mayor must provide the Council with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. The Mayor may also provide other comments. This report sets out information for the Mayor’s use in deciding what decision to make.

2 The application is referable under Categories 1B and 3F of the Schedule to the Order 2008:

Category 1B 1. Development (other than development which only comprises the provision of houses, flats, or houses and flats) which comprises or includes the erection of a building or buildings— (c) outside and with a total floorspace of more than 15,000 square metres.

Category 3F 1. Development for a use, other than residential use, which includes the provision of more than 200 car parking spaces in connection with that use.

3 Once Merton Council has resolved to determine the application, it is required to refer it back to the Mayor for his decision as to whether to direct refusal; take it over for his own determination; or allow the Council to determine it itself.

4 The Mayor of London’s statement on this case will be made available on the GLA website www.london.gov.uk. Site description

5 The 2.7 hectare application site is located in Raynes Park on the north side of Bushy Road (A298) and close to the junction with the Kingston Bypass (A3). The site is bounded by West Wimbledon Primary School to the east, a residential estate along Bodnant Gardens to the north and commercial units that will be occupied by a Next Home and Garden Store (currently under construction), to the west at 88 Bushy Road.

6 The application site is currently occupied by three main buildings, which comprise the former Thales building, a two storey 1930’s art deco office building of 5,282 sq.m., which is locally listed and is currently vacant; commercial units of 3,345 sq.m. in active retail use (Class A1) currently occupied by Pets at Home/Topps Tiles, and a standalone vacant warehouse of 999 sq.m. to the rear of the Pets at Home unit. All three buildings are separated by surface car parks. There are a number of TPO trees fronting the site on Bushey Road.

7 The site is located in an out of town centre location with Raynes Park being the closest local centre, 800 metres to the north east of the site. The site is also designated as a locally significant industrial site.

8 The A3 (Beverly Way) forms part of the Transport for London Road Network (TLRN) and the A298, Bushey Road, forms part of the Strategic Road Network (SRN). TfL is the highway authority for Beverly Way, and for both roads, TfL has a duty under the Traffic Management Act 2004 to ensure that any development does not adversely impact their operation.

9 There are a number of bus routes serving the site, with routes 265, 152 and K5 stopping on Bushey Road and providing links to , and . Bus route 131 runs

page 2 along West Barnes Lane and provide links to Kingston, Wimbledon and , although bus stops serving this route are located in excess of a 400 metres walk from the site which is used for bus planning purposes. The nearest rail station, Raynes Park, is located approximately 1.1 kilometres from the site, although is not considered to be within a reasonable walking distance. As such the site has a poor public transport access level (PTAL) of 2 on a scale of 1-6, where 6 is the highest.

Details of the proposal

10 The scheme proposes the demolition of the existing retail, office and industrial buildings on the site and the construction of a 14,931 sq.m. retail park, including 13, 737 sq.m of retail space (Class A1) and 1,193 sq.m. of cafe/restaurant (Class A3), together with access and servicing arrangements, car parking, landscaping, and associated works, including new pedestrian access to Bodnant Gardens.

11 The development will be arranged around:  an L-shaped retail terrace along the site’s northern and western boundaries, which will provide seven large-format units with 7,850 sq.m. of ground floor space and approximately 5,887 sq.m. of ‘floating’ mezzanine space that could be installed to accommodate tenant demand;  two smaller buildings in the reconstructed art deco building providing four cafe/restaurant units along Bushy Road;  a customer car park and pedestrian circulation areas around the perimeter of the car park and at its centre to connect to the new Next Home unit west of the site, in addition to a new pedestrian link to the residential estate at the rear of the site;  service and support area to the rear of the retail terrace.

12 The proposed development is for a predominantly bulky goods retail park, generating 550 new jobs (including 280 part-time jobs). The current application site currently generates 70 part time jobs (generated by Pets at Home and Topps Tiles).

Case history

13 The applicant site has no relevant strategic planning history, however, the proposal was discussed at pre-application stage with GLA officers in September 2015, where the applicant was advised about the information required to justify an out of centre retail park in particular.

14 The application is linked to the 88 Bushey Road application, which adjoins the site and received planning consent in 2014 (GLA reference: D&P/3200 and LPA reference: 13/P1802) for the construction of a 3,705 sq.m. (net) comparison retail store (occupied by Next) (Use Class A1). This development is currently under construction.

Strategic planning issues and relevant policies and guidance

15 The relevant issues and corresponding policies are as follows:

 Retail/town centre uses London Plan; Town Centres SPG;  Economic development London Plan; Land for Industry and Transport SPG;  Urban design/heritage London Plan;  Access London Plan; Accessible London SPG;

page 3  Sustainable development London Plan; Sustainable Design and Construction SPG; Mayor’s Climate Change Adaptation Strategy; Mayor’s Climate Change Mitigation and Energy Strategy; Mayor’s Water Strategy  Transport London Plan; the Mayor’s Transport Strategy; Land for Industry and Transport SPG  Parking London Plan; the Mayor’s Transport Strategy

16 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plan in force for the area is Merton’s Core Planning Strategy (adopted July 2011), Merton’s Sites and Policies Plan and Policies Map (adopted July 2014), and the 2016 London Plan (Consolidated with Alterations since 2011).

17 The National Planning Policy Framework and Planning Practice Guidance and Aecom’s London Industrial Land Supply and Economy Study (2015) commissioned by the GLA are also relevant material considerations.

Principle of development

Loss of industrial/employment land

18 The London Plan promotes a rigorous approach to industrial land management to ensure sufficient stock of land and premises is provided to meet the future needs of different types of industry and related uses in different parts of London, including good quality and affordable space. London Plan Policy 4.4 promotes an evidence based approach to reconcile demand and supply of industrial land through three types of location:

 Strategic industrial locations  Locally significant industrial sites, and  Other industrial sites (non-designated).

19 Merton’s Core Planning Strategy and Sites and Policies Plan and Map identify the application site as a locally significant industrial site (Bushey Road LSIS). The vacant Thales building and warehouse to the rear also fall within a site allocation in the Local Plan (48b), along with the committed ‘Next’ retail development next door (48a). Site Proposal 48 seeks: “An employment-led mixed use scheme, research and development (B1[b] Use Class), light industrial appropriate in a residential area (B1[c] Use Class) and storage or distribution (B8 Use Classes) that may include an appropriate mix of any of the following: bulky goods retail (A1 Use Class), car show room (sui generis Use Class) and school (D1 Use Class).” The allocation seeks employment led proposals and states that any proposed retail use at the site should be restricted to at least 70% bulky goods retail floorspace in order to avoid undue harm to the viability of town centres within the proximity of the site. The allocation excludes the Pets at Home/Topps Tile unit.

20 In relation to the industrial designation, Merton is identified in the Mayor’s Land for Industry & Transport SPG as a borough with ‘restricted transfer’ of industrial land to other uses. Through Core Strategy Policy CS12, Merton seeks to maintain and improve locally significant industrial sites in accordance with London Plan Policy 4.4. CS12 generally seeks to increase the overall number and range of jobs, particularly in the commercial and business sectors (which includes retail), seeking to increase productivity, gross values added and hence, remuneration.

21 As the proposed development for retail/leisure uses will result in the complete release of industrial uses on the site, it represents a departure from the Local Plan. With this being the case, the Council will need to consider the scheme in light of its proposed contribution towards the borough’s economic objectives, ensuring that there is an adequate supply of appropriate and

page 4 viable sites maintained, and be satisfied that this release does not undermine the provision of industrial land and functions, in particular for waste management, logistics and for SMEs/creative industries.

22 In seeking to address this point above, the applicant has commissioned a market conditions report, which suggests a lack of demand for the existing office and industrial land uses based on marketing of the site. It also notes the amount of available office and industrial stock/sites in the surrounding competing markets, including Rainbow Industrial Estate, and that a refurbishment would not be viable. In considering this aspect, the Council will need to take into account of the indicative industrial land release benchmark figures set out in the Mayor’s Land for Industry SPG for the borough and Aecom’s London Industrial Land Supply and Economy Study (2015). The Aecom report, commissioned by the GLA, suggests that industrial release benchmark in Merton for 2011-2031 is 9 hectare and a total of 5.7 hectares has already been released over the period 2010-2015. The total release of industrial land on the site would mean that Merton Council would be closed to its total benchmark for 2011 – 2031. The Council should consider whether the contribution of the existing site is outweighed by the benefits of the proposed scheme. GLA officers would benefit from local knowledge and conclusions reached by the Council to inform the Mayor’s decision making at Stage 2.

Retail

23 As an out of centre retail development, the proposals need to be assessed in the context of the impacts of the proposed additional retail floorspace on the surrounding metropolitan, major and district retail centres, in accordance with London Plan Policy 2.15, Policy 4.7 and Policy 4.8. The Local Plan, under CS12, seeks to direct ‘town centre type uses’ towards Wimbledon, , and as Major and District Centres. Policy CS7 confirms that planning permission for ‘town centre type uses’ such as retail will only be granted if the sequential test has been appropriately applied, and there is no significant adverse impact on the vitality and viability of any nearby centres. The applicant has undertaken a retail appraisal, which has been reviewed by the Council’s independent consultant, GVA. Subsequent to this, the applicant has responded to the points raised by GVA, and at the time of reporting further dialogue was taking place.

Distribution of future comparison floorspace

24 The Merton retail and town centre retail study (2011) identifies quantitative capacity of surplus expenditure at 2016 to support a further 15,200 sq.m. of comparison sales floorspace increasing to 33,200 sq.m.(44,200 sq.m. gross) up to 2021. The proposals include 13,736 sq.m.(net) of floorspace, which will take approximately 41% of floorspace capacity identified for the period up to 2021. Whilst it is accepted, there is potential capacity for additional comparison floorspace in the borough. However, noting the 3,705 sq.m.(net) of comparison floorspace in the adjacent Next store consent (D&P/3200), this would result in a total of 17,441 sq.m. (c 52%) of comparison floorspace for Merton being delivered via this site allocation, which is noted for its out of centre location. The Council should advise whether it is satisfied with the spatial distribution of future comparison floorspace within the borough resulting from the potential delivery of this scheme.

Sequential test

25 London Plan policy, in line with the NPPF, places a requirement that retail development should be subject to a sequential test with Policy 4.7 stating: (b) Retail, commercial, culture and leisure development should be focused on sites within town centres, or if no in-centre sites are

page 5 available, on sites on the edges of centres that are, or can be, well integrated with the existing centre and public transport.”

26 The applicant has completed a sequential assessment, which has particularly focussed on nine alternative sites within and at the edge of the town centres of Kingston, Wimbledon, Sutton and Morden. The sequential assessment concludes that there are no sequentially preferable sites that are available, suitable and viable that could accommodate the application proposals or a flexible interpretation of them. This conclusion is supported by the Council’s independent review by GVA.

27 Notwithstanding this, Merton Council should provide verification of this conclusion, through further consultation with Kingston Council in particular, given the concerns raised previously in relation to the adjacent Next site, and the concerns raised in the correspondence submitted as part of the retail assessment (document 2) about the cumulative effect of the proposal and consented Next scheme on future investment in the borough of Kingston. It is also noted that Council has responded to the consultation, stating that Tooting town centre has not been considered in relation to site selection and impact test. This also needs to be considered as part of the next stage of review by Merton Council and the results shared with the GLA in due course. The adjoining boroughs should be given opportunity to review the conclusions of GVA and the applicant’s response to inform Merton Council’s review and reporting of the scheme.

Assessment of impact

Impact upon town centre vitality and viability

28 The London Plan requires an assessment of impact and states under Policy 4.17 “(c) proposals for new, or extensions to existing, edge or out of centre development will be subject to an assessment of impact.” This is supported by retail policy in the NPPF. The assessment of impact is required to have particular focus on the impact of new proposed floorspace on the vitality and viability of retail centres in the London Plan town centre classification and smaller neighbourhood centres. A further requirement is an assessment of the impact on proposed investment within the town centre classification.

29 The comparison retail turnover impacts of the proposals and anticipated cumulative impacts (Table 1) are identified to occur in the following key centres in and outside the defined catchment area.

Table 1: Anticipated trading effect of the proposals (2021)

Anticipated Trading Cumulative Town Centre Impact % Impact % Baseline Sensitivity Baseline Sensitivity New Malden -1.6 -2.7 -1.7 -2.7 Colliers Wood -1.5 -2.6 (proposed centre) -2.8 -3.8 Kingston -1.3 -2.1 -1.6 -2.4 -1.1 -1.8 -1.1 -1.8 Wimbledon -0.9 -1.5 -2.4 -3.0 Sutton -0.8 -1.3 -1.4 -1.9 -0.8 -1.4 -0.8 -1.3

page 6 Morden -0.6 -1.0 -1.2 -1.6 Wandsworth -0.3 -0.5 -0.5 -0.7 Raynes Park -0.2 -0.3 -1.5 -1.6 Mitcham -0.2 -0.4 N/A N/A Tooting -0.1 -0.2 N/A N/A

30 The applicant concludes in its assessment the likely cumulative trading effects on retail turnover of existing centres by 2021 will be between -0.2% and -3.8%. It is GLA officers’ opinion that given the magnitude of trade diversion that the proposals will not have severe adverse impacts on the vitality and viability of the other centres. Notwithstanding this, Merton Council should provide assurance on possible negative impacts of the new floorspace and loss of trade on the day to day functioning of Wimbledon (major centre) and its strategic ambition of upgrading Colliers Wood to a district centre. Furthermore, as noted above, it should engage with Kingston Council to address concerns raised in relation to trade diversion impacts on its town centres.

Impact on investment

31 The applicant has assessed the potential impact of the out of centre development on in- centre planned investment in surrounding strategic centres and concludes that there is no evidence to suggest that the application proposal will lead to a significant adverse impact upon proposed investment. This conclusion is partially supported by the independent review (see below). However, Merton Council will need to provide verification on the robustness of this conclusion using its own local up to date knowledge. In particular, as noted above, it should further engage with Kingston Council on the issues raised in document 2 of the retail assessment relating to concerns raised on potential impact on a range of investment within Kingston (major centre).

Merton Council independent review report

32 The applicant’s retail appraisal has recently been independently reviewed by Merton Council’s consultant, GVA. The conclusions of the GVA report are that the scheme needs to be considered in relation to its potential impact upon planned investment in Colliers Wood in particular, noting the Council’s aspirations for it to be upgraded to a district centre. GVA has also requested further scenario testing of the impact upon town centre vitality and viability. It is noted that the applicant has provided this scenario testing, but at the time of reporting it was still be reviewed by GVA. There are also a number of conditions suggested in relation to bulky goods that need to be negotiated. Furthermore, GVA reiterate that the views of Kingston Council will need to be sought, particularly in relation to Surbiton town centre, which is a material weight in considering this application.

Conclusion

33 The independent retail review report’s conclusions and need for further verification are supported by GLA officers as they will provide assurance that the scheme’s impact on the London Plan retail hierarchy has been fully tested. There remains a need for further verification of the findings of the sequential test, impact on vitality and viability of town centres and investment in town centres. In particular, Merton Council should hold further discussions with Kingston Council across the range of issues it has raised in its consultation response to the applicant.

page 7 Urban design, heritage and access

34 At pre-application stage, concerns were raised about the layout of the proposed development, which was a very common out-of-centre format for destination retail parks. In particular, the inward looking design with retail and leisure units turning their back on the residential neighbourhood to the north was raised as a particular urban design issue, and the absence of active frontages provided to Bushy Road. The “clean-slate” approach that had been adopted for the site development with all existing buildings cleared, including the removal of the art deco office building and clock tower at 84/86 Bushy Road also raised concerns during the initial consideration of the proposals at pre-application stage.

Heritage

35 In relation to heritage assets, although not nationally listed, the art deco building and its 1930s clock tower has been locally listed for the last 24 years and is one of the few landmark buildings of character in the area of Merton. The applicant was advised that efforts should be made to integrate the building into the development layout to lift it from its functional ‘could be anywhere’ appearance.

36 In response to these concerns, the applicant is proposing to reconstruct the building in a similar style, in a different location closer to the road. The retained clock tower would be removed from the existing building and placed on top of the reconstructed two-storey building. The development proposal will be arranged as an L-shaped block of articulated warehouse-form retail units to the north with the reconstructed building next to a smaller unit to the south.

37 The applicant claims that it requires a building of the form proposed in order to serve the retail function it requires, but given the local listing of the building and its heritage values, there remain concerns about its demolition. This option, rather than the retention of the existing buildings as advised at pre-application stage, is disappointing and GLA officers are of the view that more effort should have been made to retain the existing building and its landscaped gardens (a key part of its historic and architectural significance).

38 The applicant claims that the economic benefits of the scheme outweigh the loss of heritage and its loss is less than substantial harm because it is not located in a conservation area or part of group of historic buildings. It is officers’ opinion that the building is of significant heritage value and whilst not designated, that the application should explore options for its re- use or through a facade retention scheme. Further discussion is required in relation to this aspect prior to reporting at Stage 2.

Layout and public realm

39 To the north of the site, the service area to the retail units faces on to the existing residential neighbourhood and the West Wimbledon Primary School on Bodnant Gardens. Whilst it is accepted that the location of servicing yards is a functional requirement and is generally located “back of house”, GLA officers have encouraged the applicant to address the street in some way. In light of the development being designed to be accessed by car rather than on foot via pedestrian routes, the scheme layout should make more effort to allow pedestrian access from the adjacent residential neighbourhood on foot. Although the applicant has introduced a pedestrian access from Bodnant Gardens and the adjacent neighbourhood, this appears somewhat constrained by its location and access limited by an electric sliding gate into the service bay area. GLA officers consider that the access would be better aligned with the road entrance and footpath edge for a more direct access route rather than along the back of the service yard. The applicant should also confirm that the access gate allows for free pedestrian

page 8 movement through. Some further effort should be made through mature landscaping of the edge of hard surfacing to reduce its impact. Further discussion on this aspect would be welcomed.

Climate change adaptation

40 The site is almost entirely within Flood Zone 1 with a very small portion of Flood Zone 2 and is not at significant risk of any other form of flood risk. Therefore the proposals are acceptable in terms of London Plan Policy 5.12.

41 Whilst the surface water flood risk at the site is not particularly significant, other areas in the near vicinity of the site are at significant surface water risk, therefore the management of surface water will be an important consideration for this development. The FRA states that the development will limit run-off from the site to a greenfield rate of 8l/s/ha. This will be achieved through the use of sub surface storage totalling 1454 m3. This approach provides little other benefit than storm water attenuation and is considered a missed opportunity to introduce open and green SUDS techniques. However, the proposals are considered to meet the requirements of London Plan Policy 5.13.

Climate change mitigation

Energy efficiency standards

42 A range of passive design features and demand reduction measures are proposed to reduce the carbon emissions of the proposed development. Both air permeability and heat loss parameters will be improved beyond the minimum backstop values required by building regulations. Other features include mechanical heat recovery ventilation on the retail units, low energy lighting and provision for smart metering.

43 The demand for cooling will be minimised through careful consideration of the glazing types and window locations. The applicant should provide evidence of how Policy 5.9 has been addressed to avoid overheating and minimise cooling demand. Dynamic overheating modelling in line with CIBSE Guidance TM52 and TM49 is recommended.

44 The applicant should provide the carbon emission figure in tonnes per annum for each stage of the energy hierarchy. See Table 1 and Table 2 in the latest GLA assessment guidance for the required format: https://www.london.gov.uk/what-we-do/planning/planning- applications-and-decisions/pre-planning-application-meeting-service-0. The sample BRUKL sheets including efficiency measures alone should also be provided to support the savings claimed.

District heating

45 The applicant has carried out an investigation and there are no existing or planned district heating networks within the vicinity of the proposed development. Whilst accepted, the applicant should clarify if the development is designed to allow for future connection to a district heating network should one become available.

46 The applicant should also clarify if they are proposing to install a site heat network and whether there will be a single energy centre with a centralised heating system. The heating system should be designed to be suitable for easy retrofit of district heating.

page 9

Combined Heat and Power

47 The applicant has investigated the feasibility of CHP. However, due the intermittent nature of the heat load, CHP is not proposed. The applicant should provide the estimated space heating and domestic hot water (DHW) loads of the development in order to verify this statement.

Renewable energy technologies

48 The applicant has investigated the feasibility of a range of renewable energy technologies and is proposing to install ASHP systems and photovoltaic (PV) systems. In total, 800 sq.m. of PV panels, which should be secured by condition. Further information on the operation of the heating system should be provided (i.e. individual/communal system) as well as an indicative heating and cooling schematic. The sample BRUKL sheets of the ‘be green’ scenario should be provided to support the savings claimed.

Overall carbon savings

49 A reduction of 103 tonnes of CO2 per year in regulated emissions compared to a 2013 Building Regulations compliant development is expected, equivalent to an overall saving of 35%. The carbon dioxide savings meet the target set within Policy 5.2 of the London Plan. However, the comments above should be addressed before compliance with London Plan energy policy can be verified and the carbon emission figures in tonnes per annum for each stage of the energy hierarchy should be provided.

Transport

Access

50 The application proposes to provide two vehicle access points to the site from Bushey Road. The main access will be the existing priority junction and the second will be from the new signalised access, which is being delivered as part of the new retail development adjacent to the site. This development is currently under construction and the access is being delivered through a s278 agreement with Merton Council.

51 As part of the application, the existing pedestrian access from Bushey Road will be improved, including provision of an island at the priority junction to improve crossing facilities for pedestrians and cyclists. A new link will also be provided to Bodnant Gardens from the rear of the site. This is acceptable but the applicant should respond to comments in the design section of this report.

Trip Generation, Modelling and Highway Impact

52 At the pre-application stage, TfL raised several issues that needed to be addressed to ensure the trip generation and modelling was as robust as possible to enable TfL to fully assess the impact on the traffic and public transport networks around the site. Although the trip generation has been reviewed with different sites selected, the ones used are still out of London, and unlikely to be comparable to the application site. Whilst TfL acknowledges the options are limited for the A1 land use. Suggestions were previously made and it is considered that more appropriate London-based sites are available for A3 land use. The applicant is therefore requested to undertake further work on the predicted trip generation to provide a better reflection of the development impact.

page 10

53 Considering the Retail Impact Assessment (RIA), which has looked at the likely trade drawn from the site, it was noted the tip generation was likely to differ from that presented for the neighbouring retail scheme. However, there is little information on the justification behind this and TfL would have expected more on the background to these figures to verify this.

54 Whilst TfL is satisfied with the current amendments to the signal timings, once the trip generation has been updated and agreed, depending on the outcome of the modelling, there may also be a desire/ need to signalise the existing site accesses. TfL welcomes further discussion on the above points once the information has been reviewed.

Car parking

55 The application proposes a total of 334 public car parking spaces, equivalent to one space per 46 sq.m. in line with the London Plan. Of these spaces, 22 (6%) will be accessible bays, which is welcomed, however, it is noted that the London Plan requires 6% of the spaces to be provided from the outset, with a further 4% of enlarged standard spaces for future provision. There would be 34 (10%) active electric vehicle charging points and a further 34 (10%) providing passive provision in accordance with the London Plan. It should be noted that, whilst the ratio is considered acceptable in principle, this will be confirmed once the highway impact has been agreed and assessed.

56 Two further staff car parking spaces will be located to the rear of the development. At least one of these spaces should be designed to accessible standards, as the London Plan requires one Blue Badge space to be provided for any disabled employees. It is understood that the parking control system that will be implemented at the public car park will also prevent staff parking over long periods of time. The use of cars should be strongly discouraged for all employees of the site, and TfL would expect to see initiatives to encourage sustainable travel options throughout the travel plan.

57 Section 5.7.5 of the TA includes information on the management of the car park and spaces. TfL suggests a car park management plan (CPMP) is produced for the site to provide more information on these points including the management strategy and potential impact on the surrounding area. The CPMP should be secured by condition, discharged by Merton Council in consultation with TfL prior to occupation of the development.

58 At the pre application stage, there was discussion over the provision of parent and child bays and this is also referred to in the TA, however these do not seem to be identified on the plan. Whilst there is no London Plan policy requiring these bays, TfL would support the provision.

Cycle parking

59 The development proposes to provide 100 cycle parking spaces, which includes 30 long stay and 70 short stay. Whilst TfL welcomes the quantity of cycle parking to increase security and encourage cycle travel, TfL suggests an alternative type of parking is provided for all of the long stay staff spaces, rather than the Sheffield stands.

60 Shower and changing facilities should also be available for all employees at the site, and occupiers should be required to provide these as part of their agreement rather than encouraged. Alternately, the applicant could consider a site wide approach and provide more information on this. The location of the short stay visitor parking is welcomed and distributed

page 11 across the site. The applicant should ensure that all cycle parking is located in a sheltered, accessible and well-lit area, and secured by condition.

Public transport

61 Until the trip generation has been reviewed and agreed, TfL cannot fully assess the impact the development will have on the public transport network. However, it is likely that a contribution towards bus infrastructure improvements within the vicinity of the site will be sought as a minimum.

62 Notwithstanding the above, TfL has undertaken a bus stop audit of the stops considered to be within a reasonable walking distance from the site. The findings showed that three of the shelters need upgrading and seven of the bus stops need improving, with total cost of £33,000. Therefore, TfL requests a significant contribution towards these improvements is secured through the section 106 agreement.

Pedestrian and Cycle Environment

63 TfL welcomes the applicant’s intentions to improve the walking environment through and surrounding the site, along with providing new pedestrian links. However, there are concerns with the quality of the provision. Currently the drawings submitted do not indicate the footpaths through the car park and it is unclear how pedestrians would access the retail units from the bus stops located to the south, as well as other key nodes.

64 The proposals must ensure that the effects of the development and the impact on the pedestrian and cycle networks have been considered and reflected in the design. TfL has a number of concerns about the measurements, materials and layout of the pedestrian routes, especially the access point on Bushey Road. TfL also has concerns surrounding the pedestrian environment, in particular safety, security and opening times of the new link from Bodnant gardens, and feels this could be significantly improved. London Plan Policy 6.10 states that high quality pedestrian environments should be provided and TfL welcomes further discussions with the applicant and Council to ensure the development promotes sustainable travel and provides well designed facilities to encourage walking for all users of the site. Consideration should also be given to TfL’s Pedestrian Design Guidance.

Travel Planning

65 TfL welcomes the framework travel plan submitted for the site and the measures embedded to encourage sustainable travel. The final plans including cycle vouchers/free bicycles, marketing and promotional events then be secured, delivered, monitored and funded through the section 106 agreement.

Delivery, Servicing and Construction

66 Whilst TfL is satisfied with the proposed A1 servicing arrangements, there are concerns surrounding the proposals for the A3 land uses. TfL requests additional information is provided on how the car park will be managed to ensure deliveries can stop and suggests a specific bay/s are identified. The proposal to allow deliveries to stop on the western access road out of hours is satisfactory, but there are concerns this would also be used in opening hours and cause delays. A delivery and servicing plan, in accordance with TfL guidance should be secured by condition in with London Plan Policy 6.14.

page 12 67 The outline construction logistics plan (CLP) is welcomed, and the final version should be in line with TfL guidance and secured by condition. It is understood that construction has already started at the adjacent site, this should be reflected in the CLP and programming to minimise impacts and share construction and servicing information and infrastructure where possible.

68 TfL wishes to ensure that construction vehicles are fitted with cycle specific safety equipment, including side-bars, blind spot mirrors and detection equipment to reduce the risk of collisions on the Capital’s roads. For any conflict points identified on the delivery routes associated with the site in its construction and operational state, traffic and pedestrian management measures and cycle specific safety equipment should be considered and the detail provided through the CLP and DSP.

69 In partnership with the construction industry, TfL has developed a Standard for Construction Logistics to reduce risks to vulnerable road users of construction vehicles. The Standard seeks to promote improved driving practices and use of safer vehicles. A commitment from the applicant and their primary contractors to demand a higher level of safety should form a key part of the CLP. Signing up to the Standard, as well as the Fleet Operator Recognition Scheme (FORS, or equivalent), helps in part to achieve this. Please see: http://www.tfl.gov.uk/info-for/freight/safety-and-the-environment/managing-risks-wrrr. TfL requests the applicant and their contractors sign up to this standard.

Section 106 Contributions and Community Infrastructure Levy (CIL)

70 Once the trip generation and modelling has been reviewed and agreed TfL will be in a position to provide more information on any section 106 contributions that may be sought for improvements to the highway, cycle and pedestrian routes or public transport networks.

71 The Mayor of London introduced his Community Infrastructure Levy (CIL) on 1 April 2012. Most development that receives planning permission after this date will be liable to pay this CIL. The proposed development is in the , where the charging rate is £35 per square metre of floorspace. Further details can be found at: http://www.london.gov.uk/publication/mayoral-community-infrastructure-levy.

72 Merton Council also has an adopted CIL in place, and further information can be found at http://www.merton.gov.uk/environment/planning/cil.htm. TfL acknowledges use of the borough CIL for strategic transport improvements and will discuss specific projects directly with the council.

Crossrail 2

73 In order to secure the necessary investment for Crossrail 2, the National Infrastructure Commission recommendations are clear that a demonstrable plan for delivering 200,000 homes along the route needs to be in place before 2019. This will require a full evaluation of borough and area based policies and on all sites within the vicinity of Crossrail 2 stations that could make a contribution to housing delivery. The application site and the surrounding area is within the vicinity of Raynes Park, and New Malden stations and initial work to date has identified this site as a potential location for housing in the future. Given the timings of the application and that each scheme must be considered on its merits, it is recognised that a requirement to include housing on the site is not appropriate. The Council may however wish to consider any contribution the site can make towards supporting the case for Crossrail 2. TfL has had initial discussions with both Merton and Kingston about how this area might be procured

page 13 through policy and planning to enable regeneration including housing, as well as supporting infrastructure.

Local planning authority’s position

74 Merton Council’s officers have continued to examine the various technical issues and quantifiable impacts of the proposals during the course of pre-application discussion but to date have not given full policy support for the scheme. Officers have encouraged the applicant to consider a more intensive mixed use redevelopment of the site and an element of housing as part of a mixed use development. This application is however due to be reported to Committee over summer. Legal considerations

75 Under the arrangements set out in Article 4 of the Town and Country Planning (Mayor of London) Order 2008 the Mayor is required to provide the local planning authority with a statement setting out whether he considers that the application complies with the London Plan, and his reasons for taking that view. Unless notified otherwise by the Mayor, the Council must consult the Mayor again under Article 5 of the Order if it subsequently resolves to make a draft decision on the application, in order that the Mayor may decide whether to allow the draft decision to proceed unchanged, or direct the Council under Article 6 of the Order to refuse the application, or issue a direction under Article 7 of the Order that he is to act as the local planning authority for the purpose of determining the application and any connected application.

76 There is no obligation at this present stage for the Mayor to indicate his intentions regarding a possible direction, and no such decision should be inferred from the Mayor’s statement and comments.

Financial considerations

77 There are no financial considerations at this stage. Conclusion

78 London Plan policies on the principle of development, urban design and inclusive design, climate change and transport are relevant to this application. Whilst the application is supported in principle, however, the following issues should be addressed:  Principle of development: The proposal is a departure from the development plan due to the allocation and designation of the site, including as a locally significant industrial site and needs to be more fully justify in policy and employment terms. The Council is required to consider the release of the industrial land in the context of its wider industrial land strategy.

 Retail: The Council’s independent retail review concludes that there is a need for further verification of the findings of the sequential test, impact on vitality and viability of town centres and investment in town centres report conclusions. In particular Merton Council should hold further discussions with Kingston Council across the range of issues it has raised to date.

page 14  Urban design, heritage and access: There remain concerns regarding the layout of the development and inward looking design, which do not provide active frontages onto Bushy Road and a satisfactory interface with Bodnant Gardens. The demolition and relocation of the locally listed building is not sufficiently justified and its retention and restoration into the scheme should be considered. The proposed pedestrian access to the rear of the site is indirect and convoluted.

 Climate change: The carbon dioxide savings meet the London Plan targets, however, the applicant should provide the carbon emissions after each stage of the energy hierarchy, address overheating and provide some information on the heating system proposed. The proposals are acceptable in terms of London Plan Policies 5.12 and 5.13.

 Transport: Further work is needed on the trip generation and modelling in order to establish requirements for any mitigation towards the highway and public transport networks. Information regarding Blue Badge parking spaces, car park management strategy, cycle and pedestrian routes and facilities is required, together with conditions and planning obligations.

For further information, contact GLA Planning Unit (Development & Projects Team): Stewart Murray, Assistant Director – Planning 020 7983 4271 email [email protected] Colin Wilson, Senior Manager – Development & Projects 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Hermine Sanson, Senior Strategic Planner 020 7983 4290 email [email protected]

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