No change poposed

Thank you for consulting Transport for London (TfL). I can confirm that TfL has no comments to make on the focussed changes to the pre submission Local Plan

Best wishes
Richard Carr

Increase density of site Allocation R10 Brentwood Railway Station Car Park and reflect this in the Addendum and Regulation 19 Draft Local Plan.

Transport for London Commercial Development
Dear Sir / Madam,
RE: Addendum of Focussed Changes to the Pre Submission Local Plan Consultation
Thank you for providing the opportunity to comment on the Addendum of Focussed Changes to the Pre Submission Local Plan.
Please note that our representations below are the views of the Transport for London Commercial Development (TfL CD) planning team in its capacity as a landowner in the borough only and are separate from any representations that may be made by TfL in its statutory role as the strategic transport authority for London. Our colleagues in TfL Spatial Planning may provide a separate response to this consultation in respect of TfL-wide operational and land-use planning / transport policy matters as part of their statutory duties.
TfL CD works to identify development opportunities throughout our landholdings and unlock underutilised land by pursuing innovative solutions to enable development on our sites. We are committed to providing exemplary development that will show case the Mayors objectives of providing good growth.
Brentwood Railway Station Car Park
Within Brentwood, TfL CD has identified Brentwood Railway Station Car Park as having the potential for residential development which could make a significant contribution towards meeting Brentwood and TfL housing targets.
In written representations dated 14th March 2019 (see attachment 2), we supported the principle of the Strategic Housing Allocation R10: Brentwood Railway Station Car Park, however we did not agree with the approximate capacity of 100 homes for the following reasons:
* This capacity was not in line with the content of the Draft Brentwood Town Centre Design Guide which identified that up to "405 units per hectare is suitable around key transport nodes, such as Brentwood Station."
* Brentwood Railway Station Car Park is a brownfield site, located within a town centre and adjacent to a significant transport interchange. It is, therefore, a prime opportunity to optimise housing delivery in a highly accessible location in line with National Planning Policy Framework (NPPF) paragraphs 103 and 118 (D).
* Feasibility studies indicated that a decked design could allow a greater density to be achieved on the site whilst still providing a compatible and neighbourly form of development.
* The draft site allocation boundary did not include a section of car park towards the east. The whole parcel of land which TfL has an interest in and for which we are exploring development feasibility measures 1.39ha.

Given the above, we suggested that the indicative density was increased. A density of 405 units per hectare would better reflect the sites capacity; if this figure is applied to the site area of 1.39 hectares this would equate to around 560 homes. This is considered a more realistic housing figure for the site, to ensure that the site is fully optimised and the Addendum of Focussed Changes should be amended accordingly.
We would like to emphasise that, as currently drafted, Strategic Housing Allocation R10: Brentwood Railway Station Car Park does not accurately represent the sites housing capacity. It is therefore not encouraging effective land use or optimising the potential for housing delivery on this site and conflicts with Draft London Plan policy H1 (2, a & b) which states that:
'boroughs should optimise the potential for housing delivery on all suitable and available brownfield sites through their Development Plans and planning decisions, especially the following sources of capacity:
a. sites with existing or planned public transport access levels (PTALs) 3-6 or which are located within 800m of a Tube station, rail station or town centre boundary'
b. mixed-use redevelopment of car parks and low-density retail parks'
Furthermore, if development at Brentwood Railway Station Car Park will need to re-provide existing commuter car parking, it is highly likely that higher density residential development would be required to fund the additional infrastructure associated with re-providing the parking, such as decking over the car park level or a multi-storey car park . This would be in line with the draft Brentwood Town Centre Design Guide which sets out that development should aspire to increase the density of the existing Brentwood Station area.
We therefore strongly suggest that as per the above, an increased indicative site capacity is included within the Strategic Housing Allocation R10 to accurately represent the sites housing capacity and support the redevelopment of a highly accessible, optimal site.
Concluding Remarks
We trust that we have provided sufficient information for the Council to be able to consider our representations in respect of the Addendum of Focussed Changes to the Pre