Comments received from TfL Policy in January 2019 to the draft Brent Local Plan Preferred Options, together with officer response and proposed recommended modifications to be made to the Regulation 19 version of the Draft Local Plan when submitted for Examination.

Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation 3 Spatial 3 TFL Spatial Document should Noted. Stations which will require No change Portrait Planning identify which enhancements have been referred to stations/services should within the individual place policies, be prioritised for stating some of the main improvements investment, ideally will be necessary and where, e.g. providing a list of Northwick Park Tube Station which proposals by site identifies the need to increase capacity allocation/ station. and create step free access. This can be supplemented by the Infrastructure Delivery Plan which should be updated on a more regular basis. 5.1 BCSA7 TFL Spatial TfL Commercial A response to TfL commercial who No change Central Planning Development are made a representation on this site has working on proposals for been made. The policy provides the southern portion of sufficient differentiation for the this site. The two development of the two sites, so the portions should be retention of one policy with details on under separate site each site is considered appropriate. allocations. TfL CD have commented on this in more detail. 5.2 East BEGA1 TFL Spatial Welcome safeguarding Noted. Policies elsewhere in the Plan Amend policy BEGA1 to include Planning of land for WLO, and should allow sufficient control of in planning considerations: site allocations in the development to take account of "Development around the existing surrounding area. WLO operational requirements and the or proposed rail stations and Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation is yet to receive full potential need to provide mitigation for close to infrastructure should take commitment to funding/ any impacts. There is however merit in account of operational delivery. Development being more specific about this in the requirements and the potential close to the existing/ policy BEGA1 to ensure it is considered need to provide mitigation for any proposed stations sufficiently. In relation to Neasden impacts." "Masterplanning should should account for station, it is recognised that the consider the potential for a future potential requirements development might need to mitigate bus/cycle/pedestrian link between of the rail network, and some impacts of increased patronage. Neasden Lane and Great Central associated mitigation This can also be mentioned in policy, Way and if possible allow measures. Neasden although the business case for the sufficient space within layout to station has a WLO also identifies a funding gap allow this longer term aspiration to constrained ticket hall/ which it is anticipated could be be delivered." stairway, improvements addressed through funds generated In infrastructure requirements to which should be from development in close proximity to add: "Neasden station has a considered. the line. A bus/cycle/pedestrian link constrained ticket hall and Requirement for a between Neasden Lane and Great stairways. TfL has identified that bus/cycle/pedestrian link Central Way could have big there may be a need to consider between Neasden Lane connectivity benefits and realistically station improvements to and Great Central Way, should at least be considered at the accommodate development within the Neasden initial stage of masterplanning. It is related demand, with associated Stations Growth Area however a significant piece of financial contributions." should be included infrastructure that could have within the site allocation. ramifications for the delivery of Growth Area. As it will need to cross at least one railway, the engineering will be very expensive, plus third party land interests would need to be dealt with/ add to costs. The simplest route would appear to be across the growth area with the land take required likely to reduce developable land significantly. As such, with all the other matters to address from the policy, its delivery is Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation likely to be unviable. Consideration of it as part of any masterplanning to allow for its future delivery if it can be accommodated is however prudent at this stage. As such there is merit in identifying it in the policy. 5.2 East BEGA2 TFL Spatial Development should Noted. Policy BT4 'Forming an Access Include within Planning Planning consider impacts on the on to a Road' excludes access roads Considerations: The Council TfL Road Network and being developed onto the TLRN and together with TfL will consider the its junctions, with careful London Distributor Roads. The policies extent to which the area can consideration of vehicle within the document seek to reduce support car-free development access taken. Although traffic generation from within the through suitable improvements to site has a low PTAL, borough as far as practicable. The public transport and measures to should consider Council does consider car free in lower not adversely impact on potential for car-free PTAL areas where it can be sure that it neighbours amenity of any development to mitigate can be delivered without adverse potential parking displacement. this impact, potentially impacts on occupants/neighbours. through provision of: car Given the scale of the site, identification clubs, bus of this potential is considered enhancements, and appropriate to factor in in terms of cycling infrastructure. providing any significant infrastructure requirements. 5.2 East BESA2 TFL Spatial Site not owned by TfL, Noted. The text identifies delivery of the Remove reference to site being Planning but is used by Metroline site will be subject to the retention of a owned by TfL and replace with to provide TfL bus bus depot or reprovision elsewhere. Private ownership. Amend services. Object to the The council has identified what it reference to the bus depot’s allocation of this site as considers to be under-utilised land retention or replacement to: “An it is essential to the through a number of allocations to operational bus garage of operation of the local support future housing growth. Despite equivalent capacity needs to be bus network, and is existing constraints, it is considered retained/re-provided on the site contrary to the Mayor's appropriate to identify this site, given policies on the retention suitable protection of the bus depot, or unless TfL confirms that it is no of operational transport if not needed, other employment uses longer operationally required, or a Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation land. Constrains on site as part of maximising the suitable replacement can be including limited access efficient use of land within the borough. provided elsewhere.” and proximity to rail This is similar to TfL identifying lines will make opportunities on retained operational redevelopment land, such as above stations. problematic. Site allocation should be removed. 5.3 North BNSA3 TFL Spatial Bus facilities on this site The site allocation makes reference to In planning considerations add: Planning should be retained and the existing bus stand and creating a Development close to the rail enhanced, with early new bus stand on Westmoreland Road. station and rail infrastructure will engagement with TfL It is recognised that more emphasis need to take into account London Buses. could be placed on the potential impact operational requirements and the Development close to of the development on rail infrastructure potential need to provide the rail infrastructure will and vice-versa. mitigation for any impacts need to consider and mitigate any potential impacts. 5.4 North BNWGA1 TFL Spatial As Northwick Park Noted. Planning considerations Include TfL among the West Planning station is included within identifies: "Northwick Park station’s landowners. the allocation, TfL access is via a narrow brick tunnel. No should be listed as a step free access is currently available landowner. TfL is to platforms. Development should seek working with Brent to to address these issues. increase capacity and An interchange incorporating a suitable introduce step-free bus turning point, stand and associated access. Station driver facilities will need to be improvements should be incorporated into the development. This included within will improve the connection between infrastructure the underground and buses and requirements. Welcome potentially transfer bus routes from the the intention to improve surrounding road network north of bus interchange Northwick Park Station." In addition Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation facilities, including Infrastructure Requirements identifies turning, standing, and "Improvements to the capacity of, and driver facilities. pedestrian accessibility to, Northwick Developers on site Park Station." and "An infrastructure should contribute agreement will be drawn up and signed significantly toward the by all four key partners." A such it is funding of these works. considered that the matters raised are suitably addressed, with the landowners understanding that they will have to commit to associated improvements. 5.4 North BNWSA1 TFL Policy Car parking should be The site currently has parking Include within planning West minimised due to PTAL restrictions by Sainsbury's due to its considerations: "If parking is rating, and should be proximity to the tube station/town provided it should be made made public so as to centre. Its PTAL rating means publically available and be serve the wider town residential will be car free. However designed to serve the wider town centre. Impacts on rail the need for parking to serve the wider centre." And "development close infrastructure should be town centre/ be publically available is to the rail station and rail considered and well made. Reference is made to infrastructure will need to take into mitigated. residential not being adversely account operational requirements impacted by the railway. It is agreed and the potential need to provide that reference could be made to mitigation for any impacts". ensuring development takes account of operational requirements and provides potential mitigation for any impacts. 5.5 South BP5 & TFL Spatial Point U 'enhancing the Noted. Criteria U is made in reference Include within criteria U of policy 5.5.30 Planning setting of Harlesden to improved public realm surrounding BP5 specific reference to Station and its the station. The council believe for this wayfinding and public realm connectivity to the wording to be clear, and by using the enhancements (change already surrounding area' is word 'setting' are not suggesting the made as part of Publication Plan). unclear. TfL seeks station structures/ operation Amend sentence within para clarity as to whether this themselves should be altered. For 5.5.30 as follows: 'It will be involves wayfinding and clarification on this matter additional important that the council Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation the sense of arrival, text will be included within the policy. continues to work with Network rather than changes The criteria within place policies such Rail as the owners of the affecting the station as BP5 are intended to be concise and operational rail infrastructure, in structures/ operation. therefore reference to stakeholders can addition to: TfL, OPDC, potential Point W and para 5.5.30 be made in the supporting text. See developers and community should include reference proposed changes. groups.' to co-operation with Network Rail as owners of the rail infrastructure, in addition to: TfL, OPDC, landowners, developers, and community groups. 5.5 South BSSA7 TFL Spatial Site not owned by TfL, Noted. The allocation text identifies Note now site allocation BSSA5. Planning but is used by Metroline delivery of the site will be subject to the Change ownership details to to provide TfL bus re-provision of a bus depot. The council private. Amend planning services and is believed has identified what it considers to be considerations to incorporate: An to be in private under-utilised land through a number of operational bus garage of ownership. Object to the allocations to support future housing equivalent capacity needs to be allocation of this site as growth. Despite existing constraints, it retained/re-provided on the site it is essential to the is considered appropriate to identify this unless TfL confirms that it is no operation of the local site, given suitable protection of the bus bus network, and is depot, or if not needed, other longer operationally required, or a contrary to the Mayor's employment uses on site as part of suitable replacement can be policies on the retention maximising the efficient use of land provided elsewhere. of operational transport within the borough. This is similar to land. In TfL's experience TfL identifying opportunities on retained it is extremely difficult to operational land, such as above come up with viable stations. The need to re-provide a development proposals depot that meets operational which retain the bus requirements unless it is no longer garage. This site needed/ will be provided elsewhere Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation allocation should be could also be made clearer in Planning removed. Considerations. 5.5 South BSSA8 TFL Policy Impact on rail Noted. See proposed change. Policy Note now site allocation BSSA6. infrastructure should be BT4 'Forming an Access on to a Road' Include within planning considered and excludes access roads being considerations. The development mitigated, including developed onto the TLRN and London will need to mitigate contributions towards Distributor Roads. The policies within impacts upon rail infrastructure, capacity and step free the document seek to reduce traffic and contributions toward capacity access improvements at generation from within the borough as and step free access Stonebridge Park far as practicable. improvements at Stonebridge station, especially due Park station will be sought. to the cumulative impact of development from this and other nearby sites including Northfields. Development should consider impacts on the TfL Road Network and its junctions, with careful consideration of vehicle access taken. Support development coming forward car free. 5.5 South BSSA9 TFL Spatial Impact on rail Noted. See proposed change. Policy Note now site allocation BSSA7. Planning infrastructure should be BT4 'Forming an Access on to a Road' Include within planning considered and excludes access roads being considerations. The development mitigated, including developed onto the TLRN and London will need to mitigate impacts upon contributions towards Distributor Roads. The policies within rail infrastructure, and capacity and step free the document seek to reduce traffic contributions toward capacity and access improvements at generation from within the borough as step free access improvements at Stonebridge Park far as practicable. Stonebridge Park station will be station, especially due sought. Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation to the cumulative impact of development from this and other nearby sites including Northfields. Development should consider impacts on the TfL Road Network and its junctions, with careful consideration of vehicle access taken. Support development coming forward car free. 5.7 South BSWSA1 TFL Spatial Object to the allocation Noted. The council has identified what Planning considerations to be West Planning of this site as it is it considers to be under-utilised land amended to include. An essential to the through a number of allocations to operational bus garage of operation of the local support future housing growth. Despite equivalent capacity needs to be bus network, and is existing constraints, it is considered retained/re-provided on the site contrary to the Mayor's appropriate to identify this site, given unless TfL confirms that it is no policies on the retention suitable protection of the bus depot, or longer operationally required, or a of operational transport if not needed, other employment uses suitable replacement can be land. In TfL's on site as part of maximising the experience it is efficient use of land within the borough. provided elsewhere. extremely difficult to This is similar to TfL identifying Development close to the rail come up with viable opportunities on retained operational station and rail infrastructure will development proposals land, such as above stations. It is need to take into account which retain the bus accepted that there is a need for clarity operational requirements and the garage. TfL comment on the issue of the need to re-provide a potential need to provide that this site is removed. depot that meets operational mitigation for any impacts. If it is retained, the requirements unless it is no longer Contributions will be sought planning requirements needed/ will be provided elsewhere. towards potential capacity and/or should make it clear that Thsi should be included in the Planning step free access improvements at an operational bus Considerations. IN relation to the Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation garage or equivalent of operational railway land, this also Alperton station that are likely to increased size needs to should be included in the planning be needed to accommodate the be retained on the site considerations. The capacity issue at cumulative impact of development and that this may the station is also accepted as a related trips from this and other determine the nature of relevant consideration that should be nearby sites in the Alperton surrounding incorporated. Growth Area. development. Impact on rail infrastructure should be considered and mitigated, including contributions toward capacity and step free access improvements at Alperton Station. 5.7 South BSWSA2 TFL Spatial The retention/ The policy identifies that the bus stand Amend planning considerations West Planning enhancement of Glacier should be taken account of in any after reference to the bus stand Way bus stand should proposed development. However include: "This must be retained be included as an greater clarity woud be provided by the or enhanced as part of any infrastructure amendments suggested by TfL. As development and early discussion requirement. TfL should with other sites in this area, it is also with TfL London Buses on this is be consulted early on considered appropriate to make should take place." this. Contributions suitable referene to the need for Amend infrastructure toward capacity and development to contribute to capacity requirements: Remove "No step free access and/or step free access at Alperton specific infrastructure improvements at station. requirements identified beyond" Alperton Station should and add another sentence: be included. "Contributions will be sought towards potential capacity and/or step free access improvements at Alperton station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation nearby sites in the Alperton Growth Area." 5.7 South BSWSA3 TFL Spatial Impact on rail These requests are reasonable and as Amend planning considerations to West Planning infrastructure should be such the policy can be amended to include: "Development close to considered and accommodate them. the rail station and rail mitigated, including infrastructure will need to take into contributions toward account operational requirements capacity and step free and the potential need to provide access improvements at mitigation for any impacts." Alperton Station. Amend infrastructure requirements to include: "Contributions will be sought towards potential capacity and/or step free access improvements at Alperton station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other nearby sites in the Alperton Growth Area." 5.7 South BSWSA4 TFL Spatial contributions toward These requests are reasonable and as Amend infrastructure West Planning capacity and step free such the policy can be amended to requirements to include: access improvements at accommodate them. "Contributions will be sought Alperton Station should towards potential capacity and/or be included. step free access improvements at Alperton station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other nearby sites in the Alperton Growth Area." Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation 5.7 South BSWSA5 TFL Spatial contributions toward These requests are reasonable and as Amend infrastructure West Planning capacity and step free such the policy can be amended to requirements to include: access improvements at accommodate them. "Contributions will be sought Alperton Station should towards potential capacity and/or be included. step free access improvements at Alperton station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other nearby sites in the Alperton Growth Area." 5.7 South BSWSA6 TFL Spatial contributions toward These requests are reasonable and as Amend infrastructure West Planning capacity and step free such the policy can be amended to requirements to include: access improvements at accommodate them. "Contributions will be sought Stonebridge Park towards potential capacity and/or Station should be step free access improvements at included. Stonebridge station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other nearby sites." 5.7 South BSWSA7 TFL Spatial TfL has secured a Agreed, it is reasonable to outline these Amend infrastructure West Planning mitigation package agreed provisions of transport requirements to include: including contributions infrastructure should be delivered if "Contributions to improve the bus to improve the bus amended development proposals are network, Stonebridge Park station network, Stonebridge submitted in the future. and surrounding walking/cycling Park station and routes to mitigate the impact of surrounding the development on the walking/cycling routes. It surrounding movement network." is essential that these works are carried forward into any Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation subsequent planning applications. 5.7 South BSWSA8 TFL Spatial Impact on rail Note. See proposed change. Amend planning considerations to West Planning infrastructure should be include: "Development close to considered and rail infrastructure will need to take mitigated. into account operational requirements and the potential need to provide mitigation for any impacts." Amend infrastructure requirements to include: "Contributions will be sought towards potential capacity and/or step free access improvements at Stonebridge Park station that are likely to be needed to accommodate the cumulative impact of development related trips from this and other nearby sites in the vicinity of the station." 6.8 BT1 TFL Spatial Welcome emphasis on Noted. Reference to London Plan within Appendix 4 provide the Transport Planning active travel and policy T5 will be sufficient, with the wording: "Cycle Parking application of Healthy London Plan providing the necessary Standards as set out in London Streets principles, and detail, and avoiding our repetition of it. Plan Policy T5 apply in Brent. the requirement for (already done in publication contributions toward version.) cycle infrastructure which meets/ exeeds minimum standards. Explicit reference to minimum cycle parking standards as outlined in the draft London Plan Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation should be made, in addition to reference in appendix 4. The wording of appendix 4 section 8.4.17 should make it clear the London Plan cycle parking standards in policy T5 are all minimum standards. 6.8 BT1 TFL Spatial Welcome safeguarding Noted. It has been made clear within No change Transport Planning of land for WLO, and the document that the delivery of the site allocations in the WLO is subject to feasibility testing. surrounding area. WLO is yet to receive full commitment to funding/ delivery. 6.8 BT1 TFL Spatial Should state the need to Noted. The requirement for No change Transport Planning protect infrastructure development to mitigate its impact on essential to the London's movement network is operation of the rail and included within draft London Plan policy bus networks, and T1. For concision and to reduce promote the confusion it is not the aim of the council enhancement of existing to duplicate policy which already covers facilities and the borough under National or Regional construction of new policy. infrastructure when required. 6.8 BT1 & TFL Spatial Policy should state Noted. The requirement to provide No change Transport 6.8.17b Planning potential need to transport infrastructure physically or mitigate pressure of through contributions is included within development with draft London Plan policy T4. For funding or physical concision and to reduce confusion it is Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation works. Para 6.8.17b not the aim of the council to duplicate should be expanded to policy which already covers the include the following borough under National or Regional types of work: station policy. Para 6.8.17b makes reference capacity or access to improvements in general, and does improvements, not seek to prescribe which contributions towards improvements will be necessary and bus services, priority will have to be 'viable and justifiable in measures as well as the long term'. new or improved passenger or operational transport infrastructure. Cumulative impact within an area should be assessed to identify the most appropriate mitigation. 6.8 BT2/ TFL Spatial Welcomes It is considered that the need to No change. Transport Appendix Planning encouragement of car contribute to a CPZ is addressed in the 4 free developments and first paragraph of BT2 and paragraphs the meeting of draft 6.8.16 & 6.8.17. London Plan parking maximums. Where CPZs are not already in place or where they require modification, developers should be required to contribute financially and assist implementation. Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation 6.8 BT2/ TFL Spatial The proposed Noted. Amended to state London Plan Amend Appendix 4: Parking Transport Appendix Planning employment parking standards apply for B1a uses. Standards: Parking for 4 standard of 1 space per Employment Uses 100 m2 of floor space for Opportunity/Growth 8.4.1 Parking standards for B1a Areas in appendix 4 uses as set out in the London section 8.4.2 table 1 is Plan policy T6.2 apply in Brent. not consistent with the For other employment uses in the draft London Plan policy B use class or closely related sui T6.2 which sets a generis uses, the following maximum parking standards, as detailed in Table 1, standard of 1 space per should be applied. The 600 m2 of floor space in employment areas in Brent have designated Opportunity significant variations in levels of Areas in outer London. access to public transport and The draft London Plan other individual characteristics. A policy recognises the distinction is made between areas greater potential to of the borough to the north and deliver transport the south of the Dudding Hill solutions that support railway line as this broadly reflects lower levels of parking variations in public transport and car use within provision. designated Opportunity 8.4.2. The provision of parking in Areas. The advice in new developments below the section 8.4.4 on the standards set out in the table is provision of more encouraged (see car free/car generous parking capped section). (already should be incorporated incorporated in publication in 8.4.2 to make it clear version) that any provision above the Local Plan standards should always be within London Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation Plan maximum standards. 6.8 BT3 & TFL Spatial Support minimisation of Noted. It is considered that Amend Policy BT3 paragraph 1 Transport 6.8.25 Planning road based freight, the incorporation of wording that outlines last sentence to: "The use of protection of existing encouragement of best practice and more sustainable alternatives, freight facilities, and technical innovation is appropriate. i.e.by rail and canal, and pursuit reference to of best practice in technical Construction Logistics innovation to consolidate delivery Plans and Delivery and and construction transport is Servicing Plans. encouraged." However, this should go further in encouraging consolidation and promoting good practice, safety and technological innovation for deliveries and construction transport, particularly on large development sites or on strategic routes. 6.8 BT4 TFL Spatial Support restriction on Noted. No change Transport Planning forming an access onto the TfL Road Network and London Distributor Roads. 6.8 TFL Spatial For clarity Elizabeth line Noted. See proposed change. Replace the two mentions of Transport Planning (as the name for the Crossrail with Elizabeth Line. actual service) should be used consistently throughout the document rather than Chapter Para/ Name/ Comment Summary Officer Response Proposed Change Policy Organisation Crossrail (which refers to the construction project)