Comment

Representation ID: 22628

Received: 11/10/2021

Respondent: National Highways

CONSULTATION ON THE DRAFT SUBMISSION VERSION OF THE BLACK
COUNTRY PLAN


National Highways welcomes the opportunity to provide comments on the draft
submission version of the Black Country Plan (July 2021) which covers the period up to
2039. This replaces the Black Country Core Strategy (2011) and replaces significant
elements of ‘Tier 2’ plans in the form of Area Action Plans and Site Allocations for Dudley,
Sandwell, Walsall, and Wolverhampton.
National Highways 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). It is our role to maintain the safe and efficient operation of the SRN whilst acting
as a delivery partner to national economic growth.
Within the Black Country, the SRN comprises the M5 and M6 motorways, and the A5
trunk road.
In responding to Local Plan consultations, we have regard to DfT Circular 02/2013 -
Strategic Road Network and the delivery of sustainable development (‘the Circular’) which
sets out how interactions with the Strategic Road Network should be considered in the
making of local plans. Paragraph 16 of the Circular sets out that:
“Through the production of Local Plans, development should be promoted at locations
that are or can be made sustainable, that allow for uptake of sustainable transport modes
and support wider social and health objectives, and which support existing business
sectors as well as enabling new growth.”
In addition to the DfT Circular 02/2013, the response set out below is also in accordance
with the National Planning Policy Framework (NPPF) and other relevant policies.

Based on our initial review of the draft submission version of the Plan, reports and other
supporting documents, we have identified the items below where we require further
information or clarification to help in completing our review of the draft plan: