Dear Clare Planning and Compulsory Purchase Act 2004 (As Amended); Greater London Authority Acts 1999 and 2007; Town and Country

Home , Bexley, Crayford, Falconwood

Clare Loops Strategic Planning & Growth Department: Planning London Borough of Bexley Our reference: LDF03/LDD18/CG01 Civic Offices Date: 5 April 2019 2 Watling Street Bexleyheath Kent, DA6 7AT

By email to: [email protected]

Dear Clare

Planning and Compulsory Purchase Act 2004 (as amended); Greater London Authority Acts 1999 and 2007; Town and Country Planning (Local Development) (England) Regulations 2012 Re: Consultation on Bexley’s local plan preparation. Regulation 18 stage consultation paper

Thank you for consulting the Mayor of London on Bexley’s Regulation 18 stage consultation paper. As you are aware, all development plan documents must be in general conformity with the London Plan under section 24 (1)(b) of the Planning and Compulsory Purchase Act 2004. The Mayor has afforded me delegated authority to provide comments on the emerging Local Plan on his behalf. Transport for London (TfL) has provided comments, which I endorse, and are highlighted in this letter with detailed comments attached at Annex 1.

The Mayor’s response that follows, includes suggestions and other representations to clarify and improve upon some policy areas and to ensure the document is more aligned with the draft new London Plan.

The draft new London Plan

The Mayor published his draft new London Plan for consultation on 1st December 2017 and the Minor Suggested Changes (following consultation) on 13 August 2018. The Examination in Public of the Draft London Plan commenced on 15 January 2019 with publication anticipated in Winter 2019/20. Once published, the new London Plan will form part of the Bexley Development Plan and contain the most up-to-date policies.

Given the anticipated timetable for the submission of Bexley’s draft revised Local Plan, it is likely the Local Plan will be required to be in general conformity with the new London Plan. The draft new London Plan and its evidence base are material considerations in planning decisions.

My officers have been working with Bexley on the Thamesmead and Abbey Wood (T&AWOAPF), and Bexley Riverside Opportunity Area Planning Frameworks (BROAPF). The draft T&AWOAPF is being finalised by officers and the consultation is planned to start in early summer. It will be sent to Bexley for comment shortly. Officers are currently preparing an industrial evidence based to support the development of the BROAPF. As part of this Framework, the Mayor and Bexley are in the process of

agreeing the baseline from which to calculate the industrial capacity which should inform Bexley’s evidence base on industrial need and demand. The BROAPF will set out a framework for the retention and intensification of industrial land so that there is no net loss of industrial capacity and identifying suitable sites for the release of surplus industrial land for residential development. The anticipated publication of the BROAPF is subject to discussions with Bexley and developments on C2E (Crossrail to Ebbsfleet).

Overall Strategy

The Mayor commented on Bexley’s Growth Strategy in July 2017. He broadly welcomed Bexley’s commitment to delivering increased quantities and quality of development in the borough, with a focus on the Opportunity Areas. However, he did raise concerns over the large-scale release of industrial land, which should be supported by a robust evidence base and a plan-led process, and to proposals that threaten MOL. The Vision for sustainable growth in the draft Local Plan should reflect draft London Plan Good Growth policies. The vision should note that character will change over time.

This consultation of Bexley’s Draft Local Plan is not accompanied by any evidence base. Policies set out in the next version of Bexley’s draft Plan should be informed by London and local evidence. The Mayor will be able to provide more informed comments once this evidence is published.

The London Plan sets out that growth should occur near stations as well as town centres. The supporting text of draft Local Plan policy SP2 states that areas that are only serviced by a station or a town centre are not sustainable locations. Bexley should note that demographics, lifestyles and working patterns are changing so that for some Londoners it may not be so important to be close to a station as long as there are local amenities. Appropriate levels of growth should be planned for around town centres, stations and areas of higher PTAL.

Key Diagram

The key diagram of the draft Local Plan should reflect that the London Plan designates Belvedere as a potential District Town Centre. Before this area can be designated as a District town centre, Bexley needs to set out a clear strategy that secures a broader mix of store sizes and formats and a variety of town centre uses including retail, leisure, employment and social infrastructure subject to local demand.

Housing target

The draft new London Plan sets out how London’s housing need can be met within its boundaries. The draft new London Plan sets Bexley a 10-year net housing completions target of 12,450 units (1,245 per annum). Of this target, 8,650 completions should be identified from small sites. Whilst Bexley’s Local Plan needs to consider the National Planning Policy Framework 2018, the National Practice Guidance is clear that Where a spatial development strategy has been published, local planning authorities should use the local housing need figure in the spatial development strategy and should not seek to re-visit their local housing need figure when preparing new strategic or non-strategic policies (Paragraph: 018 Reference ID: 2a-018-20180913).

Bexley’s housing target is based on the borough’s capacity on large sites, as set out in the London Strategic Housing Land Availability Assessment 2017, which Bexley fed into; and a methodology for small sites. Bexley should include its draft new London Plan housing target within its strategic housing policy.

To meet its small sites housing target, Bexley is encouraged to prepare design codes to guide small housing developments in line with draft London Plan policy H2 to promote the delivery of small sites in the borough.

Affordable housing

The Mayor welcomes Bexley’s aim to deliver 50% genuinely affordable housing over the plan period and the inclusion of the threshold approach with a threshold of 35%, in line with draft new London Plan policies H5 and H6. Bexley’s draft policy should include a threshold of 50% for public sector land and where industrial capacity is lost, in line with draft new London Plan policy H6. The next version of Bexley’s Plan should also set out its tenure split based on policy H7 and its local evidence.

Given the relatively small number of major applications, the Mayor would welcome a policy that seeks a contribution to affordable housing from smaller residential schemes.

Development in residential gardens and small sites

As stated above, a large proportion of Bexley’s housing target is made up of a target to deliver small sites. The draft new London Plan sets a presumption in favour of small sites in certain circumstances. Small sites do not need to predominantly come from developing residential gardens and Bexley is encouraged to develop design codes and set out a local approach to encourage the delivery of small sites.

Older peoples housing

The Mayor welcomes Bexley’s consideration of older peoples housing. The Local Plan Policy should set out Bexley’s commitment to meeting its target set out in draft London Plan policy H15. Bexley is advised to take note of proposed further suggested changes to the Draft New London Plan, under Matter 31, concerning the provision of specialist older persons housing and these alterations should be taken into account in future versions of the Local Plan with reference to C3 housing should be removed.

Gypsies and Traveller accommodation

The Mayor welcomes the protection of existing provision for gypsies and travellers in Bexley. Bexley should also undertake a Gypsy and Travellers Accommodation Needs Assessment using the definition of Gypsy and Traveller as set out in Policy H16 of the Draft New London Plan to inform the study. Where required, Bexley should identify and allocate potential sites for additional provision.

Industrial land

The Mayor welcomes the development of a new policies map which will make clear what industrial land is to be retained. In line with the London Plan evidence, Bexley is identified as a borough that is to retain its industrial capacity under draft new London Plan policy E4. Bexley should set out a borough-wide approach to the protection, intensification and release / co-location of Bexley’s industrial capacity. Any approach to the intensification and release of industrial land, applying the principle of no net loss of industrial floorspace capacity within SIL and LSIS, should take into account the London Plan and Local Plan evidence regarding the type of demand for industrial capacity and follow the guidance set out in the Mayor’s Practice Note on Industrial intensification and co-location through plan-led and masterplan approaches (https://www.london.gov.uk/sites/default/files/practice_note_- _industrial_intensification.pdf ). It should also take into account the local evidence being gathered as part of the BROAPF. A list of appropriate uses on industrial land are set out in draft London Plan policy E4.

Bexley should provide evidence to support policies and site allocations, indicating the most suitable places for increased industrial capacity as well as where additional industrial floorspace is most likely to be provided (including potential floorspace) based on redevelopment potential and willingness of land owners. The approach should note that SILs are London’s main reservoir of land for industry and logistics and are critical to the long term effective functioning of London’s economy. Bexley needs to demonstrate that its approach to industrial intensification is justified, effective and deliverable. Until such an approach is developed based on evidence, the Mayor cannot support the release of industrial sites in Bexley.

Whilst a limited amount of ancillary office space may be required to support industrial uses, any new B1a floorspace in industrial locations should be strictly limited, for example to upper floors/ mezzanines and managed so that B1a floorspace does not encroach on and compromise the integrity or effectiveness of existing industrial activity. Offices should be directed to Bexley’s town centres in line with draft new London Plan policies SD6 and E1 to take advantage of existing transport infrastructure and support the functions of town centres. Any exception such as for Foots Cray Business Area will need to be clearly evidenced and Bexley will need to include wider policies to improve the transport sustainability of this area (policy E1D3).

Other non-conforming uses should also be restricted and directed to town centres. Proposed paragraphs 3.17 and 3.18 are not in conformity with the London Plan as they allow for the introduction of town centre uses in SIL and could lead to the incremental erosion of SIL. The town centres elsewhere in Bexley will provide sufficient capacity to accommodate town centre uses.

Town centre

Belvedere Station As stated above regarding the Key Diagram, a clear strategy should be developed and implemented that secures a broader mix of store sizes and formats and a variety of town centre uses in line with para 2.8.4 of policy SD8 before Belvedere is designated a district town centre.

The Mayor welcomes the range of uses to be promoted in Bexley’s town centres, however the borough should take care that its restrictions on A3 uses are flexible enough to support vibrant town centres and the night time economy.

Where the Plan refers to residential uses within the town centres, Bexley should include the Agent of change principle to protect existing uses.

Building heights

Bexley should review its distance criteria set out in draft Local Plan policy DP11 given its housing target and the accepted reasonable walking distance is 800m. The proposed height limits should be assessed through a design-led approach.

Transport

With respect to transport, the Mayor welcomes the general direction of the draft Local Plan policies and TfL have issued detailed advice (Annex 1). Bexley’s ambition to reduce car use by enabling people to get around by walking, cycling and by public transport is welcomed. However, the Mayor’s Healthy Streets approach should be embedded in planning decisions and the Healthy Streets ‘wheel diagram’ should be included within the Local Plan to encourage this. The strategic ambition set out in the Mayor’s Transport Strategy that 75% of all journeys in outer London should be made by active, efficient and sustainable modes by 2041 should be reflected and promoted in Bexley’s Local Plan. The Mayor also encourages Bexley to take a more ambitious approach to the management of congestion on the road network and in making a stronger commitment to the promotion of walking, cycling and the use of public transport as an alternative to car generated journeys.

Site assessments

The Mayor welcomes the formal site assessment process that will inform the next version of the draft Plan. Bexley should take into account the evidence and detailed land use and design work that is being carried out for the Bexley Riverside Opportunity Area Framework. It is acknowledged that some sites will be suitable for industrial intensification. However following discussions with the landowner other sites identified such as Peabody’s Hailey Road Industrial Estate site (proposed Site Allocation BV008) are unlikely to come forward. As stated above regarding industrial land, without a masterplan and clear policies to deliver intensification, at this stage the Mayor cannot support the release of any sites currently designated as Primary Employment Land or Primary Employment Area.

Site SG005 – urban open space – Bexley should demonstrate that there is excess open space before the land is de-designated as open space. Masterplans should be developed for any land released from open space protection to ensure the comprehensive development of any sites.

Site CR004 – The Crayford Greyhound Stadium site should form part of a wider masterplan for the town centre before the open space designation is removed.

Next Steps I hope these comments can inform the next version of Bexley’s Local Plan. As currently drafted the Mayor has strong concerns regarding the de-designation of industrial land and the designation of Belvedere as a District Centre and considers that if these are not amended could raise issues of conformity with the London Plan. The Mayor will issue his formal opinion on general conformity when requested at the proposed publication stage. If you would like to discuss any of my representations in more detail, please contact Celeste Giusti (020 7983 4811) who will be happy to discuss and arrange a meeting. We especially encourage you to talk to us on finding ways to accommodate housing and employment growth that retain Bexley’s current industrial capacity.

Yours sincerely

pp Juliemma Mclaughlin Chief Planner

Cc: Gareth Bacon, London Assembly Constituency Nicky Gavron, Chair of London Assembly Planning Committee National Planning Casework Unit, DCLG Lucinda Turner, TfL

Annex 1 – Transport for London Comments

TfL ref: BXLY/19/83 Transport for London City Planning [email protected] 5 Endeavour Square Westfield Avenue [by email only] Stratford London E20 1JN

Phone 020 7222 5600 www.tfl.gov.uk

04 March 2019

Dear Sir/Madam,

Re: Bexley Local Plan preferred approaches to planning policies and land-use designations

Please note that these comments represent the views of Transport for London (TfL) officers and are made entirely on a "without prejudice" basis. They should not be taken to represent an indication of any subsequent Mayoral decision in relation to this matter. The comments are made from TfL’s role as a transport operator and highway authority in the area. These comments also do not necessarily represent the views of the Greater London Authority (GLA). A separate response has been prepared by TfL Commercial Development to reflect TfL’s interests as a landowner and potential developer.

Thank you for giving Transport for London (TfL) the opportunity to comment on the draft Bexley Local Plan. The draft London Plan was published in December 2017 and was open for public consultation until March 2018. Following the consultation, a revised draft was published in August 2018 showing Minor Suggested Changes made in response to consultation comments. The draft London Plan is a material consideration in assessing local policy and determining planning applications.

We welcome the aspiration of the draft local plan to support growth while enabling people to get around by walking, cycling and public transport. In particular we welcome the approach set out in the draft local plan to reduce car use. TfL will continue to work with the Council to ensure that new development enables people to travel by walking, cycling and public transport. We encourage the Healthy Streets ‘wheel diagram’ (see Appendix B) to be included in the Bexley Local Plan to fully embed the Healthy Streets Approach into planning decisions in the borough.

Sections 7.35 and 7.36 refer to a series of land-safeguarding schemes related to road- building. These have been removed from the 2041 aspirations for the approved Bexley Local Implementation Plan and are contrary to the Mayor’s Transport Strategy (MTS). We request that these schemes be removed from the local plan.

Increased capacity on the road network needs to be carefully managed to avoid wider negative impacts on the Transport for London Road Network, the Strategic Road network, local roads, and other road users including bus users and people walking and cycling. Increased capacity should also mitigate impacts on air quality, noise and public health. Any street or road improvements should be made in line with the Healthy Streets Approach and should help meet the London-wide strategic aim of 75 per cent of all journeys in outer London being made by active, efficient and sustainable modes by 2041, as set out in the MTS. This includes the need to encourage and enable shorter trips to be made by walking and cycling, and some longer trips by public transport. These measures can help improve public health through increased activity levels, supported by provision of high quality public realm. We encourage a more ambitious approach to managing congestion on the road network and a stronger commitment to mode shift to walking, cycling and public transport.

We have set out a number of comments and proposed changes on the following pages which we hope are helpful. We look forward to continuing to work together in drafting the final document and are committed to continuing to work closely with the GLA to deliver integrated planning and make the case for continued investment in transport capacity and connectivity to enable Good Growth.

Sincerely,

Josephine Vos | Acting Manager London Plan and Planning Obligations team | City Planning Email: [email protected]

Appendix A: Specific suggested edits and comments from TfL on the Bexley Local Plan

Section Page Track change/comment SP1 6 ‘High quality environments’ should also reference the importance of streets, public spaces, and reducing car dominance in placemaking, in line with the MTS. SP1 7 The vision for sustainable growth should set out how it is planned to achieve a well-connected borough, and should mention the role of walking and cycling routes in supporting MTS objectives and supporting public transport and active travel. SP1 7 The vision should seek to improve access to transport nodes, housing, employment, local services and facilities using the Healthy Streets Approach, and that people in new developments should largely be able to meet their daily needs by walking, cycling or using public transport. DP9 41- This section should contain policy text on reducing the dominance of cars in streets, public realm and in green spaces. 42 DP9 41- Developers should also consider pedestrian desire lines from/across development site towards the wider 42 neighbourhood in designing streets, cycle parking, building entrances and the surrounding public realm. 4.15 42 Please clarify which criteria are being referred to in relation to the forthcoming Design SPD. DP11 42 Consistency of language and policy is needed between this section and paragraph 4.11, which sets out a presumption against ‘tower blocks’. Please clarify what the policy is towards tall buildings within 200m of Abbey Wood and Belvedere stations. This draft suggests but does not state that tall buildings are more likely to be appropriate in these locations. Higher density development is appropriate in better connected areas and around stations. It is important to make the best use of transport investments, through ensuring that new development is appropriately dense and encourages and enables people to travel using sustainable modes. In some areas, high density development may include tall buildings.

Section Page Track change/comment 5.7 55 To meet the Mayor’s aim of 80 per cent of all trips being made by walking, cycling and public transport by 2041, it is necessary to be ambitious in achieving a shift towards sustainable modes in all London boroughs. The text in section 5.7 states that ‘the car will continue to play an important role in Bexley’. Given the relatively fixed nature of the road network and the need to make the best and most efficient use of this limited space, planning for higher levels of car use will lead to increased congestion and longer journey times. The approach to transport should be to reduce car use and to encourage and enable people to travel by walking, cycling and using public transport. These modes are more space-efficient than cars, and furthermore have wider benefits relating to health and air quality. In outer London, for the Mayor’s mode share aim to be met, car use is expected to decline over time such that only one trip in four is made by car. We suggest amending the quoted text and setting out a more ambitious approach to mode shift, particularly for shorter trips which can be done by walking and/or cycling. SP8 1g 56 We welcome the Council’s encouragement of people to walk and cycle more, and are willing to support the Council in preparing and implementing local and strategic walking and cycling programmes. SP8 1h 56 Policy SP8 1h appears to contradict the general approach set out in Policy SP8 (Bexley’s transport network). Developing road schemes is likely to induce additional car use rather than encouraging mode shift and reducing car use. It would be useful to clarify the definition of a ‘priority road scheme’ as it is difficult to indicate whether TfL would support these. Any street or road schemes should be designed using the Healthy Streets Approach. Street or road schemes that are intended to unlock or support new development should promote walking and cycling, minimise car dominance and consolidate car parking spaces where possible.

Section Page Track change/comment SP8 1i 56 Please delete the following text: ‘ensure the free flow of traffic’. While managing congestion is necessary to run an effective transport network, ensuring the free flow of vehicles (rather than people and goods) is not consistent with achieving the aims of the MTS.

Regarding ‘maintaining and managing […] car parking’, we support the Council in reducing the amount of car parking in the borough as part of the wider approach set out in Bexley’s draft local plan which supports mode shift to walking, cycling and public transport. A greater commitment to reducing car parking borough-wide is needed, however, and especially in well-connected areas. We would welcome clarity in the text regarding this commitment. SP8 1j 56 We welcome an approach to providing and managing residential car parking that is consistent with the draft London Plan, however this approach should be applied borough-wide rather than simply ‘in areas where parking needs may reduce over time through improved connectivity’. The provision of car parking in new development is a strategic issue that can have regional impacts. Where car parking is provided, this can encourage and enable trips to be made by car that could increase congestion in other boroughs. Restricting the provision of parking borough-wide is necessary to effectively manage the road network, to encourage shift to active and sustainable modes, and to improve air quality. We suggest deleting text quoted above. SP8 1k 56 The approach set out in the MTS and in the draft London Plan is to reduce both on-street and off-street car parking levels. Generally, station car parks are well connected by public transport and have amenities and services within walking and cycling distance. These are appropriate areas for higher density, car-free development. In addition to reducing car parking levels generally, re-providing car parking in these locations would be an inefficient use of land that could be better used to deliver new homes and workspaces. People generally access town centres by sustainable modes rather than by car, and people arriving by sustainable modes tend to spend more than people who arrive by car. Reducing and consolidating car parking is needed to make the best use of land and to create a better environment for spending time in, which is related to vitality more than provision of car parking is. TfL therefore cannot support Bexley’s opposition to redeveloping station or town centre car parks without reducing parking, and request that Policy SP8 1k be removed.

Section Page Track change/comment SP8 1l 56 We welcome the Council’s promotion of the Healthy Streets Approach, and suggest that this support be made more explicit by moving Policy SP8 1l higher up within Policy SP8. This should also be linked to walking and cycling as set out in Policy SP8 1g. 5.12 and 57 The supporting text at 5.12 and 5.14 appear to contradict each other. The former sets out support for a number of 5.14 road schemes and the latter supports the Healthy Streets Approach. Any road or street improvements should be designed in accordance with the Healthy Streets Approach. Increasing road capacity for cars is not in accordance with the Healthy Streets Approach, and by enabling travel by car will not help achieve a shift to walking, cycling and public transport.

Please see our comments on Policy SP8 1h above which relate to this. DP14 1 58 We welcome the promotion of walking, cycling and public transport in all development proposals. We strongly suggest that this policy apply to all developments and not just major developments. Points 1a, 1b, 1c and 1d should apply to cycling as well as walking. DP14 1 58 We strongly support point 1e which sets out that cycle parking should be provided in accordance with the standards set out in the London Plan as a minimum. DP14 1j 58 Please clarify what is meant by ‘ensure good access to and within areas served by networks’. DP14 1l 58 Please amend text: “ensure direct, secure safe, accessible and pleasant walking routes to stops” DP14 1p 58 Car clubs are not considered a sustainable transport mode and car club use, therefore, does not count towards the Mayor’s mode share aim. Car clubs can play a role in reducing car ownership, but this can only be ensured when paired with an overall reduction in parking spaces. Otherwise car use might actually increase as car-free households have access to a car and other residents continue to own cars at the same rate. As such, any car club spaces count towards the maximum for car parking spaces and should only be provided where car parking is otherwise permitted. Where car parking is permitted, we support car club provision in lieu of private parking.

Section Page Track change/comment 5.16 59 We welcome the use of the London Cycling Design Standards in the design of all cycle parking. 5.17 59 We strongly support the approach set out in section 5.17 regarding the implementation of DP 14, and welcome the Council’s recognition that reducing car parking can free up land for other uses, making streets more attractive, promoting health, and optimising use of space. 5.21 59 Most of Bexley has access to public transport (please see Appendix C for Public Transport Access Levels in the borough). Bexleyheath town centre, at PTAL 6a, has the highest level of public transport connectivity in Bexley. The text stating that ‘the Council has concerns that a lack of parking in Bexley, particularly for residential and employment uses is creating traffic flow, safety and amenity issues through excessive on-street parking’ does not align with the approach set out elsewhere in the draft local plan, especially the point made in section 5.17 regarding car parking not being an optimum use of space.

Where there are concerns that new development may generate car use, the appropriate approach is to encourage and enable travel by walking, cycling and public transport. This can be achieved through designing new development in accordance with the Healthy Streets Approach, through local improvements to walking and cycling routes, and through developer contributions for new or improved public transport infrastructure and services. Car parking should be restricted and only provided where permitted by the London Plan standards. Where new development may create on- street parking pressure, we recommend implementing a Controlled Parking Zone (CPZ), which can enable existing residents to park more safely and conveniently. TfL is willing to help in the design and implementation of CPZs.

Section Page Track change/comment DP 15 1a 60 We welcome the Council’s approach to car parking in adopting London Plan standards as Bexley’s local standards, however we have reservations regarding the proposed maximums in areas of PTAL 0, PTAL 1 and PTAL 2. Maximums in these areas should be no higher than those set out in the draft London Plan: up to 1.5 spaces per dwelling in areas of PTAL 0 or PTAL 1, and up to 1 space per dwelling for areas of PTAL 2.

PTAL 2 covers a large area of Bexley. Different areas of PTAL 2 can have varying access to town centres, frequent public transport, and amenities and services. The areas of PTAL 2 that are within active travel distance of stations (for example Albany Park, Bexley, Crayford, and Falconwood stations) are likely to see higher levels of development than other areas of PTAL 2. It is important therefore to manage the provision of car parking in these areas without adopting higher car parking standards than those set out in the draft London Plan. DP 15 1b 60 Minimum car parking should only be adopted when justified by robust evidence and should never be applied borough- wide. It is not appropriate to request minimum levels of car parking for ‘major applications’. We request that Policy DP15 1b is removed. DP 15 1c 60 Car parking standards for Use Classes B2-B8 that are higher than those set out in draft London Plan should only be adopted or applied following an evidence-based, borough-wide approach to the provision of car parking. Such evidence should identify specific parts of the borough where higher standards could apply, in accordance with draft London Plan Policy T6.2 D. A degree of flexibility may be applied to reflect different trip-generating characteristics – this should be clearly set out in Bexley’s local plan and evidence base. DP 15 1d 60 The approach to provision of car parking at residential care homes (Use Class Order C2) should be the same as the general residential car parking standards. It may be appropriate to provide limited levels of car parking for employees given site context, and to account for shift patterns that start or end during periods of lower public transport frequency or reduced connectivity, for example during the night.

Section Page Track change/comment DP 15 2a 60 TfL recommends adopting an approach that encourages and enables car-free development. Where car-free or car-lite development may cause spillover on-street car parking, we recommend extending the boundaries of a CPZ or introducing a new one. A CPZ can be implemented that restricts residents in new developments from applying for a parking permit, while allowing existing residents to apply for one. This can help existing residents to park more safely and conveniently. This is in line with Policy DP15 2b of the draft local plan. TfL is willing to assist in CPZ implementation, including advising on consultation material, especially where this would support car-free development. DP 15 2b 60 TfL supports restricting residents in new development in CPZs from applying for a parking permit. 60 We recommend including as another point in Policy DP15 2 that sets out that car parking levels in new development should be related to public transport access, and that development in better connected areas should be car-free for all use classes. 5.23 60 Please amend text: ‘Where car parking is provided in new development, this must Developments must provide a level of parking, which does not significantly impact on residential amenity, safety, vehicle, cycle or pedestrian flow or access and must be is appropriately maintained, managed and enforced to achieve these outcomes. This may include mitigating the loss of existing parking where necessary. Parking brought forward in connection with major development proposals will need to be accompanied by a Car Parking Design and Management Plan, which will allow the flexible management of the parking spaces. The preferred approach set-out above will ensure that parking standards are locally appropriate. With regards to minimum standards, this will depend on the scale of the development and local factors including parking stress and general highway conditions.’

The draft London Plan sets out an approach to car parking standards that enables car parking minimums to be set in specifically identified areas of PTAL 0 and PTAL 1 only, as part of a borough-wide car parking strategy. Any proposals for minimum standards must be justified by robust evidence. Where there is local parking stress around a proposed new development, the appropriate approach is to implement a CPZ and not to apply a minimum car parking ratio.

Section Page Track change/comment 5.24 and 61 The proposed car parking standards are not fully in line with the draft London Plan and should be revised to reflect the 5.25 draft London Plan approach. The draft London Plan takes account of the geography of London and of varying public transport access levels, and the standards vary accordingly. Where a development may lead to overspill on-street parking, the preferred approach is to implement a CPZ to manage demand. A CPZ can be used to restrict residents of a new development from applying for a parking permit, prioritising on-street car parking for existing residents. 5.26 61 Transport Assessments should be in prepared accordance with TfL’s latest online guidance available at https://tfl.gov.uk/info-for/urban-planning-and-construction/transport-assessment-guide/transport- assessments?intcmp=10094 5.27 61 Please amend text: ‘Waiting and turning space should be available for ambulances, dial-a-ride vehicles etc. only where it is demonstrated that these are not available on-street.’ 5.29 61 Provision of car parking in town centres should be minimised, as town centres generally are well connected by public transport and have higher levels of congestion. Discouraging people from driving into town centres is necessary to manage the road network and to encourage walking and cycling. Reducing car parking in town centres and ensuring that new development is car-free in Metropolitan and Major town centres can help to discourage car use. New development in town centres should therefore only provide car parking where there is a demonstrated need and where it is in line with the draft London Plan car parking policies. 5.30 61 Any motorcycle parking should be considered on a case by case basis, and where provided count towards the maximum permitted for car parking spaces, in accordance with paragraph 10.6.7 under Policy T6 of the draft London Plan. 5.31 62 Please amend text: “Therefore, all developments which are likely to generate significant amounts of movement should be supported by a Transport Assessment or Transport Statement and a Travel Plan in accordance with TfL’s latest online guidance.”

Section Page Track change/comment DP16 2 62 New development should have no negative effects on the safety of any users, and should aim to have a net positive effect on safety in accordance with the Mayor’s Vision Zero policy to eliminate death and serious injuries from London’s roads by 2041. It is not enough to state that ‘proposals should not have a significant negative effect on the safety of any users’ in terms of the impact of new development on the transport network. DP16 3 62 New development should mitigate any negative impacts on the operation or efficiency of the Local and Strategic transport network or the public transport network. Mitigation measures should be sought through agreements with TfL and the London Borough of Bexley. 5.35 62 Please amend text: “The purpose of Travel Plans, Delivery and Servicing Plans, and outline Construction Logistics plans are to encourage more efficient use of the transport system and reduce private vehicle car use. This is achieved through the identification and implementation of various measures such as car sharing enabling people to walk, cycling and use public transport, or the scheduling of deliveries outside of peak traffic times. Such measures can make a significant and cost-effective contribution to mitigating development impacts on the transport network. Further guidance is available from TfL28 5.36 63 We welcome the approach to mitigating the impact of development by requiring applicants to make off-site improvements to walking and cycling routes. We encourage extending this to include other improvements such as requirements for applicants to provide cycle parking at nearby stations and town centres, and also to consider the cumulative impact of development so that all applicants make appropriate contributions to mitigating impacts and enabling people to walk and cycle. Site 225 We strongly resist losing bus garage facilities, which are necessary for running an effective public transport system in allocation London. Policy T3 C and Table 10.1 of the draft London Plan set out that development proposals that do not BH003 adequately protect bus garages (among other infrastructure) without suitable alternative provision being made should be refused.

Section Page Track change/comment Site 164 Crossrail South East Section Project Land: allocation Part of the car park underneath Harrow Manorway flyover should be allocated to the Abbey Wood station cycle hub, TA002 for which the borough has received funding.

Appendix B: Healthy Streets Wheel

Appendix C: Map of Public Transport Access Level (PTAL) in Bexley