Chapter 6 - TRANSPORT

6.1 INTRODUCTION

6.1.1 Policies in this chapter are concerned with the integration of land-use decisions with decisions on transport investment and management - within the locational framework in the part I (strategy) section of the Plan - this way reliance on the private car can be reduced. The policies relate to the transport impact of development, and to new transport proposals with land-use implications.

6.1.2 The level of resources available for transport investment cannot be predicted over the lifetime of the Plan. The Council's interim transport plan (to become a local implementation plan for the Mayor of London's Integrated Transport Strategy) will roll forward spending proposals annually. The Council is also in the process of reviewing its Road Safety Plan, developing a Road Traffic Reduction Plan and an Air Quality Action Plan (which will be drawn together within the new local implementation plan), which also set out detailed measures for implementation taken in the light of the policies in the Unitary Development Plan. The UDP has also had full regard to these complementary strategies.

6.1.3 Many of the measures that will need to be implemented fall outside the control of planning, or the Borough. Brent's transport problems do not begin or end at its borders. A sustainable transport strategy for Brent is only meaningful as one piece in the jigsaw of a sustainable transport strategy for London - implemented in partnership with transport operators and the various London-wide transport bodies. The most important contribution of planning to this is to influence the design, amount of parking, traffic and environmental impact, and location of new development.

6.2 BACKGROUND

Existing Transport Conditions

6.2.1 The Borough has a complex road and rail- based public transport network, with: 45 daytime bus routes, 5 night bus routes, serving nearly 600 stops, and 26 Network Rail and London Underground stations. Although, overall, rail/tube infrastructure is good, the Borough suffers from poor interchange in key regeneration areas such as Park Royal, Wembley and Harlesden. Linkages between bus and tube/rail, and between tube lines need to be improved.

6.2.2 The North Circular Road (A406) is the backbone of the road network in Brent, and broadly divides the more suburban north of the Borough from the more densely urbanised south. It is the main orbital road within North London but, as a consequence, there is severe pollution and noise impacts upon the residential areas adjoining it.

6.2.3 On-street parking problems are extensive in shopping areas, in older industrial and commercial areas and older terraced streets and in areas around underground and rail stations.

6.2.4 In Brent car ownership is low when compared with national levels; 37% of households have no access to a car, with marked variations throughout the Borough (source 2001 census). Most trips made by Brent residents are within Brent or to other parts of outer north-west London. Only 16% of all daily trips are made into Central London (source LATS 1991).
The Problems This Causes

6.2.5 The trend is for traffic levels to continue to grow, with increasing Brent car ownership and use and decreasing journey speeds in London. This growth has had unacceptable consequences including:

1) Economic Impacts
• Congestion affecting the ability of firms to obtain and make deliveries and to attract a workforce;
• Discouraging inward investment in urban areas.
2) Social Impacts
• Affecting and limiting choices of non-car transport modes, such as cycling, walking and buses;
• The social & health problems (e.g. stress) resulting from long and difficult commuting times;
• Safety of vulnerable road users, in particular children and the elderly.
3) Environmental Impacts
• Poor air quality and the consequent impact on public health;
• Noise & vibration;
• The severance and visual impact of transport, both directly and indirectly, on the form and appearance of places;
• The loss of non-renewable resources, e.g. oil;
• The effect on global warming through the release of green house gases.

6.2.6 Traffic growth within a limited capacity of road network inevitably produces traffic congestion, which has exacerbated the problems listed above. For example slow moving traffic has a greater air quality impact. But improving traffic movement universally, however, might simply encourage car traffic growth, and could lead to a shift away from public transport.

6.2.7 The advantages of non-car modes in reducing these problems is illustrated below:

Table for chapter 6

6.2.8 One of the main concerns is over poor air quality. This is worst on major roads such as the North Circular Road, where lead and particulate matter (pm10 ) levels, arising principally from commercial vehicles, create a severe public health problem. Residential properties along such roads also suffer from unacceptably high noise levels.

6.2.9 Also, the regeneration of some areas may be hindered unless the public transport infrastructure can be upgraded to cope with planned development and local residents are able to travel to work using alternatives to the private car.

6.3 STRATEGIC CONTEXT

The Government's Integrated Transport White Paper 1998

6.3.1 The main theme of the White Paper is integration which it defines as: integration within and between different types of transport to make connections work; between transport and environment policy for a better environment; with land use planning to reduce the need to travel; and between transport and our policies on education, health and wealth creation so that transport helps make a fairer, more inclusive society.

6.3.2 The White Paper aims to achieve a better balance so that people are encouraged to reduce car usage in favour of more environmentally friendly modes, such as public transport. Amongst the planning related measures proposed are:

1. New income streams for local authorities to tackle pollution and congestion by levying charges for driving into town centres and for workplace parking;
2. Interim Transport Plans (in the case of London), to deliver five-year strategies to meet local needs. These will cover all forms of transport and include local targets for improving air quality, road safety, walking and cycling, public transport and road traffic reduction. In London this will take the form of an Integrated Transport Strategy to be drawn up by the proposed Mayor with the boroughs bidding for funding through 'Local Implementation Plans';
3. Greater investment in bus services, through up-graded Quality Partnerships between local authorities and operators;
4. A Strategic Rail Authority, which will take on the task of managing passenger railway franchising, driving up service quality;
5. Better Land Use Planning; it proposes emphasising access to leisure, jobs and services by foot, bicycle and public transport. Policies for parking should support this. Development plans should better safeguard facilities for sustainable transport. New housing should avoid undue reliance on the car. Future development in Brent, along with future spatial plans, should complement the Council’s Local Implementation Plan for Transport. Where appropriate, proposed (journey generating) development, such as major places of employment/residential proposals, should be supported by a Sustainable Travel Plan, where it is anticipated a development may generate significant additional journeys. As a result, major development should only take place where excellent , dedicated, public transport can be guaranteed.
Guidance on Preparing Full Local Transport Plans 2000

6.3.3 This stresses the importance of integrating local transport plans and development plans, and that ideally their preparation should take place in parallel. Authorities need to undertake a fundamental review of their transport strategy. Planning polices on parking need to minimise the level of parking associated with development through the adoption of maximum standards. In London, boroughs will have to prepare local implementation plans of how they intend to implement the Mayor’s Transport Strategy.

PPG12 Development Plans (1999)

6.3.4 This stresses the role of development plans in integrating transport and land use policies. The development plan strategy should underpin the land use issues arising from the implementation of a local transport plan. Development plans should include specific policies and proposals on the overall development of the transport network and related services. Traffic reduction and air quality targets should be included.

6.3.5 There is a strong presumption against the building of new roads unless all other options (assessed through a multi-modal appraisal including of public transport improvements) are shown to be impractical (para 5.18). It states “alternative uses related to sustainable transport should be considered first for sites now surplus to transport requirements” (para 5.23).

PPG13: Transport (2001)

6.3.6 The guidance aims to promote more sustainable transport choices and reduce the need to travel, especially by car. It stresses that strategies in the development plan and the transport plan should complement each other and that consideration of development plan allocations and local transport investment and priorities are closely linked.

6.3.7 Amongst the main planning policies that it promotes is to focus major generators of travel demand in town and district centres and near to major transport interchanges and to locate day to day facilities in local centres so that they are accessible by walking and cycling. A key planning objective is to ensure that jobs, shopping, leisure and services are highly accessible by public transport, walking and cycling. It particularly stresses contributing to social inclusion by ensuring that development is accessible by public transport from deprived areas. It requires parking policies which restrain the overall amount of parking to reduce reliance on the car for work and other journeys.

6.3.8 It requires development plans to allocate sites for intensive development, potentially mixed-use, where these are highly accessible by non-car modes, and conversely allocate or re-allocate sites unlikely to be well served by non-car modes for uses which are not travel intensive. It states that “Developers putting forward large development proposals (possibly incorporating a number of individual elements) which involve major travel demand need to be flexible in terms of considering the potential for tailoring, reducing, or splitting projects so that they can be accommodated in the preferred locations or on existing sites, particularly those which are highly accessible by non-car modes.” (para 27).

6.3.9 It recommends negotiating improvements to public transport as part of development proposals, in order to reduce the need to travel by car and parking at such sites. It states “The development plan should indicate the likely nature and scope of contributions which will be sought towards transport improvements as part of development in particularly areas or on key sites. This will give a greater certainty to developers as to what will be expected as part of development proposals and also provide a firmer basis for investment decisions in the plan area.” (para 83). Transport assessments should be submitted with major developments and should illustrate the likely modal split of journeys, and details of proposed measures to improve public transport, walking and cycling and reduce the number and impact of motorised journeys associated with the development. The role of green transport plans is stressed in this regard, and these can be required where transport impact is a particular concern.

The National Air Quality Strategy (1997) and accompanying circulars (15/97)
6.3.10 This sets out a new system of local air quality management in which local authorities will take the lead. Local authorities are required to identify and designate Air Quality Management Areas (AQMAs), with air quality action plans setting out how acceptable levels of air quality can be reached by 2005. Development Plans and Air Quality Action Plans should have regard to each other, and it is stressed that the impact of a development on air quality is a material planning consideration.

Mayor of London Transport Strategy (2001)

6.3.11 The (London) Mayor’s Transport Strategy is being implemented, in the main, by the interim Local Implementation Plan, 2001 (ILIP), and since then, via the annual Borough Spending Plan (BSP) submissions. A statutory document which will supersede the ‘ILIP’, known as the ‘LIP’ (Local Implementation Plan), will be developed by Brent and all London Boroughs between July 2004 and December 2005. This Process begins with the preparation of a draft LIP, following consultation with the Boroughs, carried out during April/May 2004. The Council has submitted a comprehensive response to the Draft LIP Guidance, which is attached to this document. It is stated, that the policies and proposals set out in the Strategy should, over the next ten years, noticeably reduce the growth in traffic that would occur across Greater London if present trends were to continue. In outer London, recognising that the car will remain the dominant means of travel, even with the Strategy’s proposed improvements to public transport, walking and cycling, the net effect is likely to be a reduction in the growth in traffic by a third to 5% , over the next ten years.

6.3.12 Boroughs are encouraged to introduce local measures to reduce this growth further. The lower level of growth in outer London will happen over a longer timescale, in particular reflecting longer term changes in population and land use patterns. In outer London town centres there is the potential to achieve zero growth, particularly where through traffic can be removed. The traffic reductions that are actually achieved will be influenced by the range of measures introduced at the local level by boroughs, as well as Londonwide initiatives. Action by all London’s local authorities will be required if the targets are to be attained. The Mayor will support local borough initiatives that aim to achieve greater reductions in traffic in specific areas, especially in town centres and where traffic goes through unsuitable areas, and will assist the boroughs in meeting their obligations under the Road Traffic Reduction Act 1997.

Regional Planning Guidance for the South East (RPG9, 2001)

6.3.13 This sets out the regional transport strategy for the South-East. It states that the management of future travel demand will be a crucial aspect of this, including restraint on car parking. It sets down a range for maximum parking standards for B1 uses within Outer London. In the South-East a more rigorous approach towards parking standards is required than in PPG13.

Strategic Guidance for London Planning Authorities (RPG3, 1996)

6.3.14 Encourages boroughs to “work in partnership with both public transport operators and private developers in linking development sites with improved public transport infrastructure and interchange points, and in maximising developer contributions” (para 7.9). It advises that boroughs should safeguard new rail infrastructure in UDPs. It also advises the mapping of the London Bus Network, and the inclusion of plan priorities promoting good access by and to, buses in new development.

6.3.15 The guidance emphasises the importance of plan policies promoting walking and cycling. On parking policy it encourages boroughs “to seek a balanced approach which recognises the legitimate need for parking to meet economic objectives and enhance the respective position of their areas but set that against the environmentally damaging effects of traffic movement and the impact of parked cars.” (Para 7.46). It sets down maximum parking standards Londonwide for employment generating land-uses.

West London Transport Strategy

6.3.16 The importance of Brent's transport system within West London must be stressed. West London functions as the national gateway to Central London from much of the north-west and south-west of the country, and as the international gateway into Central London from the busiest international airport in the world (Heathrow). The National Stadium will also become a focus for national and international trips. For this reason it is essential that Brent's strategy is compatible with those of other West London Boroughs. Consequently West London Leadership has prepared an integrated transport strategy for West London for this purpose, focussing on improving radial links and improving integration at major regeneration locations.

The Draft London Plan (Spatial Development Strategy For Greater London)

6.3.17 The Draft London Plan emphasises that transport planning and spatial development must be integrated. It states that good public transport access, the provision of means of travel such as walking, cycling and the use of buses, and a reduction in dependence on the private car are all necessary conditions for sustainable development. Development generating large amounts of travel needs to be concentrated where adequate public transport capacity exists or is planned.

6.3.18 In promoting reduced dependence on the private car it is recognised that control over the inefficient and unattractive use of scarce land for car parking is necessary. The Draft London Plan includes maximum parking standards to be taken into account when drawing up UDP policies and standards, whilst taking account of local circumstances.

6.4 POLICY OBJECTIVES

6.4.1 Taking into account the background to transport in the Borough, and the various requirements of Government policy and guidance, the objectives of the Unitary Development Plan's policies towards transport are as follows:

1. To reduce the environmental by-products of traffic, such as noise, vehicle emissions and accidents;
2. To reduce the need to travel, especially by the private car. To promote social inclusion by planning for houses, jobs and local facilities in close proximity and ensuring access for the whole community to development, whilst minimising severance of communities by traffic;
3. To co-ordinate planning and regeneration to achieve transport improvements which enhance the attractiveness of regeneration areas, as well as ensuring that development in regenera tion areas is designed and located so that it is attractive to access by public transport, where necessary by securing service improvements;
4. To ensure that the Borough's residents, workforce and visitors have real choices in the means of transport they use, and that it is convenient, frequent and reliable, in a Borough free of excessive traffic volumes and congested parking. In particular to improve the quality of accessibility by public transport, walking and cycling;
5. To make better use of existing roadspace reducing the environmental impact of traffic by prioritising sustainable modes of transport - such as walking, cycling and buses - in managing traffic. Using this to minimise the amount of roadbuilding to principally that which essential to secure access to poorly accessed regeneration areas;
6. To ensure that the needs for freight transport and servicing are met - including a greater emphasis on non-road based freight transport;
7. To ensure that planning decisions support the targets set in the Borough's Air Quality Strategy, Traffic Reduction Plan and Road Safety Strategy.

6.5 BOROUGH STRATEGY

6.5.1 The three key aims of the UDP - Improving the environment, regenerating run down areas and providing access for the whole community - are conflicting if unsustainable modes, such as the private car, predominate. Transport is very rarely an end in itself - its role is to facilitate social and economic activities. Therefore land use decisions need to be integrated with the public transport network and the development of an integrated transport system linked to regeneration programmes and environmental improvement. Integration also needs to be more comprehensive; there needs to be sufficient public transport to take journeys shifted from the private car, it also requires a greater emphasis to the neglected mode of transport that does the integrating - i.e. walking - and on means of integration, such as interchange facilities. Public transport will not be used unless there are walkable environments at the beginning and end of the public transport component of the journey.

6.5.2 The Borough strategy is to focus transport investment, especially public transport investment, in support of key regeneration opportunities (including town centres which are the areas most likely to be accessible by public transport) and to provide additional capacity in areas of high demand, in order to achieve a significant shift away from the use of the private car. This will be reinforced by restricting parking in developments and increasing on-street parking controls. Focusing development in these areas can also reduce the need to travel, by locating jobs, homes and services in proximity to each of these.

6.5.3 The problem for rail and underground is a lack of services on some lines and lack of interchange facilities. For the road based transport system improvements will require a re-allocation of road space away from cars towards public transport, cycling and walking.

6.5.4 Early attention needs to be given to reducing those types of car-borne trips that can be most easily shifted to more sustainable modes. Examples include trips carrying children to and from school, shorter trips than can be easily made by foot and cycle, and work trips to town centres and other areas with good public transport. Longer term measures need to be focused on the more difficult issue of commuter and shopper journeys, although some measures can have an early impact - such as parking restraint.

6.5.5 With the national shift away from building roads, priority needs to be given to making better use of existing roads. The table below sets out a framework for doing this in Brent. This cannot mean simply increasing their capacity to take through traffic - this is likely to be counterproductive and have unacceptable air quality implications. Priority is given to the movement of 'people and goods' rather than vehicles per-se.
Framework for Making Better Use of Brent's Roads
i) First priority is given to ensuring that the management of roadspace improves road safety. Public transport is the safest mode;
ii) It will not be possible to manage this roadspace in line with the current rates of growth in car ownership and use. To improve air quality and to free road capacity for road based public transport and cycling it will be necessary to plan for and implement measures which control this trend;
iii) All of Brent's roads are part of the wider London Road Network. The top tiers of this need to take essential through traffic, such as freight, as well as buses prioritised through traffic management measures such as segregation, priority routing and signalling - and other through trips which cannot presently be transferred to public transport;
iv) It is environmentally unacceptable for through traffic to use local residential roads, hence steps need to be taken to remove this traffic, such as traffic calming and management measures. In considering such measures, the highway authority will consult with local residents, businesses and the emergency services;
v) The Planning and Highway Authority will consider whether or not the through traffic generated or attracted by development is acceptable in terms of the capacity and functions of the Strategic Road Network and London Distributor Roads, whilst wholly discounting any potential any local roads may have for carrying through traffic;
vi) To ensure that there is road capacity to meet these aims there will be a need to extend on-street parking controls, as well as introducing traffic restraint measures such as restricting private non-residential parking.

POLICIES AND PROPOSALS

6.6 THE TRANSPORT IMPACT OF DEVELOPMENT PROPOSALS

6.6.1 The traditional method of dealing with the impact of traffic from development has been superseded by requirements for a more comprehensive assessment of impact, via transport impact assessment. This looks at what impact development has on travel patterns for all modes of transport, i.e. walking cycling, car-use, public transport etc.

6.6.2 Note: The allocation in the Plan of areas for development or redevelopment carries no guarantee that particular proposals submitted for planning permission will be acceptable on transport grounds, either to the Borough, or (where relevant) other bodies with a role as highways authority (i.e. adjoining boroughs on boundary roads, the Traffic Director for London and/or the Department of Transport. In many cases a detailed view of the transport implications of a development can only be formed at the time the application is submitted, and in the light of up to date highway and public transport capacity, and environmental information.

Transport Assessments

6.6.3 Major and other developments likely to have a significant transport impact should be submitted with a formal Transport Impact Assessment (TIA). This is a written statement providing detailed information on the range of transport conditions both before and after a proposed development has been built, including details on how existing conditions are likely to change as a result of any other committed development or transportation proposals in the area. These should cover all modes of transport including public transport, walking and cycling. If there is not a full Environmental Statement (Policy EP1) accompanying the planning application, then the effect of additional traffic on air pollution and noise should also be included. For smaller schemes, aspects of their transport impact would still need to be assessed through the normal development control process (against the policies of the Plan).

6.6.4 It is important that TIAs are objective and accurate assessments of a proposal rather than simply promotional literature. They need to positively identify & tackle the transport problems associated with a development and suggest solutions. For this reason it is not recommended that they are prepared after a development is designed but instead in parallel with the early design stages. In many cases, such as where a development is for a specific occupier, it will be possible to incorporate proposed traffic reduction measures (e.g. green commuter plans) with the TIA; in such cases their inclusion will be a requirement. For speculative outline schemes, conditions should be placed on the outline consents requiring such plans to be submitted and approved by the local planning authority, when the appropriate reserved matters are determined.

TRN1 TRANSPORT ASSESSMENT

Planning applications will be assessed, as appropriate, for their transport impact, including cumulative impacts - on the environment and on the road network, and all transport modes, including: public transport, walking and cycling.

Developments having a potentially significant impact on the transport network should submit a Transport Assessment (TA). This should incorporate proposed traffic reduction measures by the developer (e.g. Green Transport Plans).

Where this transport impact is demonstrated to have an unacceptable public transport or environmental impact (as defined in policies TRN2 & TRN3) then the application will be refused, unless measures are secured as part of the application (policy TRN4) making this acceptable.


Public Transport Integration

6.6.5 Policy TRN2 judges the harm that can potentially result when development is proposed without the necessary public transport infrastructure and/or services to access it sustainably. The impact of good public transport by itself is likely to be low in that it is a necessary but not sufficient condition for public transport patronage. Most will still drive if they have access to a parking space at the end of a journey. Therefore the policy needs to be read alongside the Plan's restraint-based policy on parking for non-residential development (Policy TRN22), which mean that most trips to the development will need to be by public transport; and the Plan's policy on the 'Sequential Approach' (Policy STR2) which requires development attracting significant numbers of people, in the first instance, to be located in town centres. As the new parking standards are much lower than the parking demand for most uses, these uses may not be appropriate in locations where a deficiency in public transport means that unacceptable on-street parking will occur; especially where there are not sufficient on-street parking controls to contain this, and/or where this would significantly increase the number and/or length of journeys by the private car.

6.6.6 Integration: To provide an attractive alternative to the car, public transport must operate as a true network. Existing measures such as the Londonwide travelcard and Londonwide bus network planning need to be built on to provide more through-ticketing, better connections and co-ordination of services, wider availability of information and improved waiting facilities. The Government has commissioned the Chartered Institute of Transport (CIT) to produce an audit or check-list to address a wide range of possible interchange improvements (concentrating in most detail on physical aspects of interchange).

TRN2 PUBLIC TRANSPORT INTEGRATION

Development should benefit and not harm the
operation of the public transport network, and should be located where the public transport accessibility is sufficient to service the scale and intensity of the use; in particular:

(a) The capacity of the public transport network, within convenient and safe walking distance of the site, should be sufficient to accommodate any increase in passenger trips to an acceptable level of service;
(b) Any significant increase in traffic generated by development, and/or associated highway works, should not cause material harm to the speed and/or reliability of bus services, especially on the London Bus Priority Network; and
(c) The proposal should make proper opportunity for interchange facilities between public transport modes or services.


Environmental Impact of Traffic

6.6.7 Apart from the impact on public transport there are a range of other environmental issues that comprise transport impact. There are both direct environmental effects (e.g. noise), and indirect effects arising from congestion, such as nuisance, loss of air quality, etc.

6.6.8 Although the transport impact of a development may be acceptable to the highway authority in terms of its legal obligations on capacity, traffic reduction, safety etc., the planning authority must consider wider issues in making it's decision e.g. noise from traffic, inconvenience to existing highway users from generated traffic etc.

TRN3 ENVIRONMENTAL IMPACT OF TRAFFIC

Where a planning application would cause or worsen an unacceptable environmental impact from traffic generated it will be refused, including where:

(a) The anticipated level of car generation/attraction is greater than the parking to be provided on site in accordance with the Plan's standards and any resulting on-street parking would cause unacceptable traffic management problems; and/or
(b) The proposal would have unacceptable environmental problems such as noise or air quality (especially affecting air quality management areas); and/or
(c) The development would not be easily and safely accessible to pedestrians and/or cyclists; and/or
(d) Additional traffic generated would have unacceptable consequences in terms of access/convenience for pedestrians and/or cyclists; and/or
(e) The proposals would produce unacceptable road safety problems; and/or
(f) The capacity of the highway network is unable to cope with additional traffic without producing unacceptable levels of traffic congestion - especially where this would hinder the ability of the Strategic Road Network and/or London Distributor Roads to cope with through trips, or would introduce through traffic onto local roads; and/or
(g) The proposal would cause a significant increase in the number and/or the length of journeys made by the private car.


Making Transport Impact Acceptable

6.6.9 Where the transport impact of development proposals would be unacceptable according to the preceding policies, the planning and highway authorities will consider what measures, if any, may be possible to acceptably mitigate this. National policy supports the use of such measures (RPG3 para 6.9, PPG13 paras 6-12-6.14, Circular 1/97 para B10), including the use of contributions to improve accessibility through improved public transport or other appropriate forms of infrastructure - not necessarily those immediately confined to the site. These measures will be strictly and proportionally related to the development in question, which may include access improvements to the area in which the development is situated, and will not be used to relieve existing problems unless the development would exacerbate an already unacceptable situation. Not every development can be made acceptable in transport terms; sometimes it might just be the wrong use in the wrong location or it might require a thorough redesign or a reduction in scale.

6.6.10 Where the Plan's new 'restraint based' parking standards (policy TRN22) are applied there is the danger of unacceptable on-street parking where limited or no on-street parking controls exist. A contribution towards bringing forward an existing programmed scheme, or creating a new scheme, may help tackle this problem (see Policy TRN25).

6.6.11 The organisation that would occupy a development can also help by producing company strategies such as 'green transport plans'. These can be of significant benefit in encouraging, for example, employees or other users of a development to reduce their car-use, and are now tax-free. A good Green Transport Plan should preferably include annual % targets for car-reduction and include management arrangements to continuously map and monitor car-use and travel patterns of employees with incentives and information to employees to reduce car-use. These incentives should ideally be subject to monitoring and review at least every two years and this shall be the responsibility of a named manager. Some examples of the measures that should be considered include:

• Car sharing;
• Travel awareness and incentives to walk, cycle and/or use public transport;
• Flexitime and staggered working hours;
• Teleworking;
• Communal travel arrangements for employees (e.g. coaches); and
• Local recruiting and training arrangements.

6.6.12 Public transport contributions; Whilst it is desirable for developments to be located close to the public transport network, it is recognised that for some areas, particularly certain parts of some regeneration areas, developments attracting significant numbers of people could be acceptable providing there are public transport improvements, in order for the overall transport impact to be acceptable. Improvements could take the form of new capital items or revenue costs such as new or enhanced bus or rail services that provide links to a development or from the development to existing town and/or local centres and major facilities such as hospitals.

6.6.13 Such improvements will be sought where the public transport impact of the development is unacceptable (Policy TRN2), for schemes attracting significant numbers of people, having regards to the following normal minimum thresholds for seeking public transport improvement obligations - also having regard to the intensity of the use:

i] Where the capacity of the public transport network is unacceptable (only the very largest schemes);
ii] In areas of low public transport accessibility, for schemes of 250m2 or over;
iii] In areas of moderate public transport accessibility, for schemes of 500m2 or over.

6.6.14 Two fundamental issues need to be addressed when considering developer contributions towards public transport, particularly for revenue support of services. Firstly, developer contributions for public transport may not be an adequate substitute for a development that is poorly located as, even after the contributions, the site may not be as accessible as other sites, such as those in town centres. It needs to be considered, therefore, whether the improvements make public transport a genuine alternative to car use such that it will significantly affect the modal split of travel to a development. Secondly, any contribution might only be over the short term (e.g. 3 years) but the services provided needs to be viable in the medium term. The main purpose of revenue contributions therefore should be for 'pump priming'. Money is needed because the early stages of a development may not generate enough demand to justify services being provided in their own right. However, it is always necessary to provide public transport early in the life of a development to ensure that people have a choice of transport modes and do not become dependent on car use. It will not be sufficient to anticipate that operators will service a development - this should be discussed with the operators and the planning authority at an early stage.

6.6.15 Securing Developer Contributions; As a general rule developer contributions will be sought to secure transport improvements sufficient to overcome any transport impact objections arising from the development.

6.6.16 If what could reasonably be sought through developer contributions from a single planning obligation, is not sufficient to overcome transport objections, and it is desirable that the scheme goes ahead on regeneration grounds, then the approach in these circumstances may be:

(i) To grant permission subject to a condition linking the implementation of the development or phases of the development to specific improvements (subject to the requirements of relevant transport authorities); or
(ii) To secure from the developer a contribution to the cost of infrastructure improvements; or
(iii) To secure from the developer a contribution designed to enable a project which is already programmed to be brought forward; or
(iv) For a number of developers to contribute jointly to the improvements required, such as through an infrastructure accord, .

TRN4 MEASURES TO MAKE TRANSPORT IMPACT ACCEPTABLE

Where transport impact is unacceptable, measures will be considered, individually or in combination, which could acceptably mitigate this and enable the development to go ahead - and where necessary secured at the developers expense, including:

(a) Public transport improvements sufficient to service the scheme or to integrate it with the surrounding area: Developments attracting a significant number of trips in areas with low or moderate public transport accessibility will only be acceptable when significant public transport improvements (particularly to bus facilities and/or services) are secured which are both viable and justifiable in the longer term;
(b) The extension or bringing forward of on-street parking controls/waiting restrictions;
(c) Improvements to pedestrian and/or cycle facilities;
(d) Traffic calming measures;
(e) Acceptable road safety and essential highway improvements, not necessarily restricted to junctions and road lengths adjacent to the development, providing these improvements are limited to measures necessary to make the transport impact acceptable; and
(f) Management measures to reduce car usage to an acceptable level (e.g. green transport plans).

Such measures should be necessary for the scheme to go ahead and be related to the development, should be consistent with any existing or proposed parking controls and Local Area Transport Strategy (Policy TRN22) covering the area, and should not unacceptably divert traffic problems elsewhere.

Wherever possible measures should be completed before the development is completed/ operational.


New Transport Infrastructure - Assessing Impact

6.6.17 Brent has adopted a common framework for the assessment of the design and other environmental impacts of transport infrastructure in line with the approach to assessment outlined in the Integrated Transport White Paper. This policy covers both new public transport infrastructure, new roads proposed under Policy TRN17 and other new highway proposals (such as junction improvements).

6.6.18 Sufficient attention must be paid to the impact of such improvements on the full range of transport modes. For example new roundabouts permitted as part of new developments have made movements more difficult for pedestrians, cyclists and buses. For this reason large roundabouts or pedestrian subways may now be unacceptable.

6.6.18a Under the Disability Discrimination Act, from 2004 buildings and transport infrastructure would require reasonable alterations to to provide access for disabled people (see DETR "Guidelines in Design of Interchanges, Terminals and Stops”).

TRN5 TRANSPORT INFRASTRUCTURE - DESIGN AND ENVIRONMENTAL CONSIDERATIONS

Proposals for new transport infrastructure (including associated street furniture) will be assessed against the following criteria:

(a) They should not undermine the role of a road within the London Road Network (Policy TRN16);
(b) Where necessary area wide traffic calming facilities should be included to prevent inappropriate traffic using local roads through residential areas. Proposals should not unacceptably divert traffic problems elsewhere;
(c) New roads or highway proposals should not be at the expense of alternative public transport improvements, which could have comparable benefits with fewer environmental problems;
(d) They should not result in significant loss of housing, community or employment premises, or areas of importance to nature conservation;
(e) They should not result in greater severance of local communities; and
(f) They should make a positive contribution to the public realm and/or the setting of open spaces or buildings (especially concerning conservation areas and listed buildings).
(g) They should not have an adverse impact on the ease of movement for pedestrians, cyclists and people with disabilities.


6.7 PUBLIC TRANSPORT

Public Transport Accessibility

6.7.1 Transport for London have produced a map of how accessible different parts of London are to public transport. This is intended to help boroughs, transport operators and regulators, and above all the future Mayor, plan for better public transport. Its main functions will be to help to:

• Decide what sorts of development should be located in what parts of London;
• Decide where public transport frequency and/or routes should be increased;
• Show those parts of London where a reduction in the use of the private car might most easily be achieved.

6.7.2 The accessibility map works by mapping London according to public transport accessibility levels. The higher the level the more accessible a site is to London's public transport network. Brent uses it as the basis of its policies which relate the location, form and intensity of development to the public transport necessary to serve it in a sustainable manner (Part I Policy STR5). Hence developments that attract significant numbers of people, such as new shopping and leisure facilities, should be located in areas with the highest levels. Otherwise experience shows that too many people will use their cars to get to them and the traffic and environmental problems will get worse. The Borough is divided into four categories of Public Transport Accessibility (PT Accessibility) - see Map TRN1. It should be noted that the description of 'good' and 'low' etc. are relative to Brent. By national standards areas this is quite good, but measured by Central London standards is poor.

6.7.3 It is a simple measure based on adding up the walking time to a public transport stop to the average waiting time once there. If there is a real choice of public transport services (e.g. more than one station or multiple bus routes) then the higher the level will be. Being a deliberately simple measure however, it can only be used to judge just one aspect of the quality of public transport in an area. Other things that need to be assessed are the quality of public transport interchanges, the capacity of stations and the public transport network in general, how walkable links to public transport stops are and how efficient the public transport network is in an area in order to be able to get from a to b. Looking at the public transport level of a site should, therefore, be just the starting point of judging whether public transport is good enough there.

6.7.4 The parts of Brent with the highest public transport level are generally town centres. Hence these should be the focus for intensive development. Areas close to stations and along main bus routes may also have high levels where there is a good frequency of service. Developers may be able to upgrade the public transport level of a site by paying for new facilities/services/ increased frequencies (Policy TRN4). However, it is very difficult to significantly alter the London Public Transport Accessibility Map unless the scale of new development can pay for major upgrading. Permitting development in areas with poor public transport accessibility in the hope or expectation that it can improve can lead to people's car use patterns becoming set, which are then very difficult to change. For all of these reasons the London Public Transport Accessibility Map should be seen as a tool for applying the government's sequential approach directing intensive development to the most sustainable locations. This will help ensure that developments are accessible to the whole community, not just those with access to a car.

Development at Transport Interchanges

6.7.5 There are a number of tube and rail stations in Brent that are proposed to have, or already have, potential for comprehensive upgrading incorporating bus-interchange facilities; some in connection with the National Stadium proposals. These will become, or are already, focal points with good public transport accessibility and, as such, will be appropriate for high density development with a mix of land uses (see Built Environment Chapter, Policy BE11).

TRN6 INTENSIVE DEVELOPMENT AT SELECTED TRANSPORT INTERCHANGES

Intensive development is supported on appropriate sites at/adjoining the following existing or proposed transport interchanges:

• Kilburn (Jubilee Line);
• Kilburn High Road;
• Park Royal Interchange (see Policy PR5);
• Queens Park;
• Willesden Junction Hub;
• Wembley Central (see Policy WEM30);
• Wembley Park (see Policy WEM31);
• Wembley Stadium (see Policy WEM32).

Development should make full and effective use of the site, have a mix of land uses, (if required to by Policy BE11) and should be orientated around pedestrians, buses and cyclists (with good links to the transport interchange), rather than the private car.

The phasing and nature of development should ensure that it complements the comprehensive development of the area.


Rail and Underground

6.7.6 The Borough is served by 25 underground and rail stations. Lines to the Midlands, the Chilterns, the North West of England and to Scotland pass through the Borough.

6.7.7 The main problems associated with parts of the existing network are infrequent and unreliable services, difficulties of access for those with mobility difficulties; poor quality of stations and inadequate interchange facilities. The following are the key proposed rail/underground improvements affecting the Borough which have a reasonable prospect of going ahead:

• Three Stations strategy for Wembley; Redevelopment of Wembley Park, Wembley Stadium and Wembley Central stations to provide adequate capacity for the intensive train service (approaching a peak of 100 trains per hour) which will be necessary to ensure the success of the new National Stadium as a public transport venue. Details of these proposals and associated development is contained in a special policy within the Wembley Regeneration Area Inset Plan Chapter (policy WEM 10).
• Orbital Rail Services; Potential for continued improved services on the North and West London lines, new stations on the West London line and the longer term potential to link these as part of an 'outer circle line';
• Channel Tunnel; Connections from the Borough to the terminus at St Pancras and the international station at Stratford. Direct access to these international stations will be possible via Metropolitan and Jubilee/North London lines respectively. There is also the potential for direct Channel Tunnel services to the National Stadium if under-used freight track (in the Hythe Road area in Hammersmith & Fulham) is upgraded to establish a link between the West London Line and the Dudding Hill Line. Tunnel freight services already use Willesden-Brent sidings for marshalling;
• The Chiltern Line; Proposals for enhanced frequency of services and station improvements (Chiltern Metro);
• East-West Crossrail; Formal safeguarding directions protect the proposed East-West Crossrail line to protect it from alternative development, but no implementation package has been put in place.
• Park Royal Interchange; The Council, in conjunction with the London Borough of Ealing, is seeking the provision of a new Central Line Station with a link to the Piccadilly line as part of the Park Royal Western Gateway development proposals, with improved pedestrian access and bus interchange facilities (see Policy PR5);
• Intermediate Modes; London Transport (now Transport for London) published a series of proposals for 'intermediate modes'. In terms of capital expenditure and capacity they would be 'intermediate' between buses and rail and can take a number of forms including guided busways, trolleybuses and trams/light rail. The Council has examined long term options for provision of an intermediate mode route from Wembley to Park Royal Interchange.
• Willesden Junction Hub; Rebuilding of the ticket office, an improved Station approach, bus turn-around and waiting area, and bus/rail interchange. Brent supports an additional phase of the project to re-instate the main line platforms;

New Rail and Underground Infrastructure

6.7.8 The main proposals in the Borough for the provision of new rail and underground infrastructure, other than those associated with the National Stadium, are listed in the policy below. Of these projects only the East-West Crossrail scheme involves a statutory safeguarding line. All other projects involve existing operational or highway land.

6.7.9 In most cases new stations will require permission in not being fully contained within operational land, and as they contain additional non-operational uses. The location of new stations is not under the control of the Borough but is the responsibility of those responsible for the track and rail/tube services. However, the Council can promote the building or rebuilding of stations - especially where these are related to development proposals.

TRN7 NEW RAIL AND UNDERGROUND INFRASTRUCTURE

The following new Rail and Underground infrastructure projects are supported, and will, where necessary, be safeguarded:

(a) East-West Crossrail; The area shown on the proposals map is safeguarded, as required by the Government;
(b) Park Royal Interchange; As a necessary requirement of large scale trip-attracting development here (see Policy PR5);
(c) Willesden Junction Hub.
Planning decisions should ensure that development proposals are fully integrated with these.

TRN8 NEW RAIL STATIONS - DESIGN CONSIDERATIONS

The upgrading of existing stations, and the formation of new interchange facilities on appropriate sites, is supported. These should, where practical, have:

(a) A visual impact and setting appropriate for a building which is be a community focal point and landmark;
(b) Interchange facilities with buses;
(c) Disabled access from buses and the street to trains (where there are no separate requirements under the building regulations);
(d) Adequate secure cycle parking facilities; and
(e) Good lighting and have good community safety arrangements for passengers, both when staffed and unstaffed.

continue to next part of Chapter 6

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