brentwood.gov.uk

FOR THE ATTENTION OF: The Planning Team
Brentwood Local Plan Response
Dear sirs,
Thank you for giving Highways England (HE) the opportunity to comment upon the Draft Local Development Plan setting out your development needs, policies and strategies over the next 15 years. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
In the case of the Draft Local Development Plan, Highways England is interested in the potential impact that the development might have upon the M25 Junctions 28 and 29 and the A12. We would be concerned as to whether there would be any adverse safety implications or material increase in queues and delays on the strategic road network as a result of your Local Plan developments.
We have reviewed the Draft Development Plan and have the following comments
Policy 6.3 C covering general development criteria states that development proposals will need to be accompanied by transport assessments to ensure that the transport network can accommodate the generated traffic. We would caution against examining development impacts on a site by site basis only as this may overlook the impacts of Local Plan development as a whole. Looking at the Housing Land Allocations in Figure 7.2 there are numerous small sites that would have no impact upon the A12 or M25 although the aggregate impact for the smaller sites fully built out could add to queueing and delays on the two SRN roads within the Borough. There should be a transport assessment of the overall Local Plan developments and the need for any mitigation identified. We would need to be assured by evidence that the overall Local Plan development has been considered if we are to support the Local Plan.
We are pleased to see in Policy 6.3 C that you stipulate a requirement to consider safety as part of a transport assessment. Given the high speed nature of the M25 and A12 safety is a primary concern to Highways England and we would object to any safety implications of development, development traffic or highway mitigation.
As you know, in 2014 we were consulted by you and made comments on your suggested approach to the transport assessment for your Local Plan at that time. We have not heard further to this time any more details of an assessment but assume that you will still be undertaking such an assessment. We look forward to receiving your full Local Plan transport assessment in due course. Should you require further advice on transport related issues please do not hesitate to contact us.
Policy 8.8 relates to retail and commercial development. The policy calls for mitigation to the transport network where travel demand cannot be accommodated satisfactorily. Again, this approach suggests that any impacts are examined on an individual development basis. There is a risk in adopting this approach downstream for two reasons. Firstly, the full impacts of the local plan will not be considered, rather assessment of the larger developments only. Secondly, full impacts should be assessed within the Local Plan rather than at planning application stage, otherwise mitigation may be required that for whatever reason may be undeliverable.
Policy 10.1 covers sustainable transport. We are pleased to see a dedicated policy covering sustainable transport measures in addition to Policy 8.3 stating the need to locate development in accessible areas close to the arterial corridors M25, A12 and A127. To marry the two policies there will be a need to develop sustainable transport measures that manage down the private vehicle demand to and from these accessible developments. Policy 8.3 also states the need for employment development to be accessible by walking and cycling. Therefore, we will be keen to see what measures are to be adopted under your Local Plan to ensure that these policies are compatible.
We hope that you find these comments useful and we look forward to further correspondence in due course.
Sent on behalf of Janice Burgess (Spatial Planning Manager)