Commercial Development FutureMerton Team 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 Page 2 of 13 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. Page 3 of 13 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.