Comment

Representation ID: 21246

Received: 11/10/2021

Respondent: Newlands Developments

Transport (Section 9)
Draft Policy TRAN1 (Priorities for the Development of the Transport Network) advises that key transport corridors will be prioritised through the delivery of infrastructure to support active travel (walking, cycling), public transport improvements, traffic management (including localised junction improvements) and road safety. Part 4 of Draft Policy TRAN1 also emphasises that key transport priorities identified for delivery during the lifetime of the Black Country Plan currently include M6 Junction 10 and key road corridors, including the A454.

Linked to the above, Draft Policy TRAN4 (The Efficient Movement of Freight) also encourages road-based freight to use the Key Route Network whenever practicable. In addition, Draft Policy TRAN4 advises that junction improvements and routeing strategies will be focused on those parts of the highway network evidenced as being of particular importance for freight access to employment sites and the motorway network. We strongly support Draft Policies TRAN1 and TRAN4, especially as the ongoing investment and improvement of committed transport priorities and projects, including to M6 Junction 10 and the Black Country Route (A454) which are located approximately 2km to the south of the Site, reinforces the suitability of the Site for a high quality employment development as it will be adequately serviced by a variety of travel modes. These transport improvements will support the scale of growth proposed at the Site and within the wider Core Regeneration Area, and will also facilitate improved access to the Site for local communities.

Paragraph 113 of the NPPF advises that all developments that will generate significant amounts of movement should be required to provide a Travel Plan, and the application should be supported by a Transport Statement or Transport Assessment so that the likely impacts of the proposal can be assessed. As such, we are supportive of Draft Policy TRAN3 (Managing Transport Impacts of New Development), which is consistent with NPPF Paragraph 113, emphasising that Transport Assessments and Travel Plans produced by developers are essential to demonstrate that an acceptable level of accessibility and safety can be achieved using all modes of transport to, from and through the development.

Draft Policy TRAN5 (Creating Coherent Networks for Cycling and Walking) also encourages new developments to create an environment that encourages sustainable travel via safe and direct links that connect to existing walking and cycling networks, and good walking and cycling links to public transport nodes and interchanges. We are generally supportive of this policy as it accords with the requirements of Paragraph 110 of the NPPF, which advises that in assessing sites that may be allocated for development in plans, it should be ensured that appropriate opportunities to promote sustainable transport modes can be taken up, and that safe and suitable access to the site can be achieved from all users.

Parking

Draft Policy TRAN7 (Parking Management) identifies that the Black Country Authorities will ensure a consistent approach to maximum parking standards is enforced in new developments, as set out in supplementary planning documents.

Whilst it is considered important to promote sustainable transport methods as part of new developments, the provision of parking is critical to the success of logistics schemes. Indeed, where a logistics development is in operation for 24-hours a day, it can mean a shift change takes place overnight where public transport is either limited or not available.

a. achieve a 19% carbon reduction improvement upon the requirements within Building Regulations Approved Document, Part L 2013, or achieve any higher standard than this that is required under new national planning policy or building regulations; and, in addition
b. incorporate generation of energy from renewable or low carbon sources sufficient to off-set at least 20% of the estimated residual energy demand of the development on completion.

We would therefore recommend that draft Policy TRAN7 is amended to confirm that maximum parking standards would not relate to logistics developments.