
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.