It is recommended that the policy wording is amended to address the points raised in order to remove ambiguity and provide clarity for the decision maker in relevant planning applications.

3. Effective
4. Consistent with National Policy

The principle of the policy to consider car limited development in appropriate locations is supported. NPPF, paragraph 102, seeks to promote opportunities for walking, cycling and public transport use, along with ensuring parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

The policy makes reference to car limited development being considered at Brentwood Town Centre or District Shopping Centres, railway stations or strategic employment sites. As worded it is unclear why locations have been separated into the two alternatives, or in drafting the policy is the intention to refer to all these locations individually when considering car-limited development?

Paragraph 2.34 of the LP defines the 'District Shopping Centres' as being Shenfield Hutton Road, Ingatestone High Street, Warley Hill (Brentwood Station). It is considered reasonable that car limited development could be considered at these locations, as they are in close proximity to walking, cycling and passenger transport modes, including rail stations. However, they would need to consider other policies in the plan.

However, it is unclear how car limited development will be considered at Strategic Employment Allocations, of which only Brentwood Enterprise Park is thus defined. It is unclear how it would be expected that employees will be expected to travel via safe and direct walking and cycling routes given its location at M25, J29, without significant improvements to the sustainable transport network, including the provision of new passenger transport services.

However, criteria b and c, as worded, is repeated through Policy BE13 - Sustainable Means of Travel and Walkable Streets, which prioritises cycle and pedestrian movements and access to public transport.

It is unclear how the methods identified in criteria d. would be implemented.

Thank you for consulting Transport for London (TfL). We have previously responded to the Site Allocations Reg. 18 consultation (attached) and our comments remain valid although it should be noted that the full opening of the Elizabeth Line and hence the transfer of safeguarding powers from Crossrail Ltd to TfL has now been delayed. An announcement on a revised timescale is expected shortly. Colleagues in TfL Commercial Development will respond separately regarding the site at Brentwood Station Car Park in which they have a potential development interest

In addition TfL has the following comments to make on Local Plan policies:

Policy BE11 A and B and Para. 5.96
TfL supports the intention to maximise the value of railway connectivity and specifically the improvements brought by the Elizabeth Line by ensuring that new development is well connected to rail stations by foot, cycle and public transport and introducing parking controls where necessary. Prioritising access to stations by sustainable modes of transport and seeking improvements to links, access, public realm and station capacity through developer contributions, alongside parking controls, is consistent with the approach being taken in London. TfL notes the reference to TfL rail services and the Elizabeth Line in 5.96. As stated above the revised timescale for the start of Elizabeth Line services is to be announced shortly.

Policy BE11C
As highway authority for the A12 and A127 roads within London TfL welcomes the intention to seek highway improvements and particularly to seek suitable non highway measures and/or improvements to walking and cycling that may help to mitigate traffic impacts as a result of development. When assessing impacts and providing mitigation, the cross boundary impacts of new development on the Transport for Road Network within London should be taken into account

5.106 - 5.107
We agree with the outlined approach of working with relevant bodies regarding the impact of the Lower Thames Crossing and any mitigations that are needed on the A127, A12 and local road network, and would be happy to work with you and other bodies to ensure the appropriate mitigation is delivered

Policy BE12 - Car limited development
TfL welcomes the inclusion of a policy on car limited development which reflects the approach being taken in London

Policy BE13 - Sustainable means of travel and walkable streets
TfL welcomes the priority given to walking, cycling and public transport and the aim of facilitating sustainable modes of transport through new development. Again this is broadly consistent with the approach being taken in London. However, we would be grateful if mention could be made of the Healthy Streets Approach that is being implemented in London through the Mayor's Transport Strategy and Policy T2 of the draft London Plan

Policy BE16 - Mitigating the transport impacts of development
TfL welcomes the requirement to submit Transport Assessments/Statements and the requirement for mitigation where necessary
Best wishes
Richard Carr