Comment

Representation ID: 45897

Received: 11/10/2021

Respondent: Transport for West Midlands

Elements of this policy are welcomed, particularly in terms of transferring freight onto sustainable modes of transport like rail and waterways with some of the policy thinking echoing that of TfWM’s own Regional Freight Strategy, which will be updated in light of the new WM LTP. However, there are no policies on management measures in the form of restrictions on daytime road deliveries, consolidation initiatives or favourable policy in support driver facilities.

In particular, this policy section would benefit from addressing the role of consolidation centres for towns and opportunities for smaller logistics operations for last mile, such as local neighbourhood micro-consolidation facilities, improved routing software together with integrated online sales systems. The inefficiencies of the last mile problem have only been compounded by the continuous rise of ecommerce in retail, which has dramatically increased the number of parcels delivered, as well as raised customer expectations for fast delivery.

Policy TRAN4 could also address the use of cargo and eCargo bikes, ZEVs in freight and the use of micromobility and mobility hubs (including parcel lockers). In particular, supporting the shift toward ZEVs within the freight industry could be noted explicitly in this policy together with meeting the refueling needs, through appropriate freight charging stations as part of new development. Adopting cleaner technologies (to help meet air quality improvement goals laid down by the government) is also vitally important, especially as freight vehicles currently account for a disproportionately high percentage of harmful air pollutants.

There are also no policies which capture the importance of safety with regards construction vehicles or how these must not hinder sustainable and active travel infrastructure, especially for those more vulnerable road users. Potentially capturing the importance of Delivery and Servicing Plans and Constructions and Logistics Plans, as well as adherence to the Construction and Logistics Community Safety Scheme (CLOCS) could help minimise the impact both HGVs and LGVs will have on the surrounding highway, brought about through new development and construction. Also, in new developments themselves, the importance of ensuring good road safety measures is vital and needs capturing in this policy.

Freight parking requirements are also missing from this policy section, and TfWM would welcome exploration into potential sites for lorry holding areas as well as good off-street servicing facilities and provision of facilities for home deliveries within new developments, whilst not impacting on the wider public realm.

More explicit reference to the Major Road Network (MRN) should also be noted in the plan. This new category of economically important ‘A’ roads, and Large Local Majors (LLM) schemes (focusing on significant upgrades to local roads) will help unlock housing and economic growth and support the Strategic Road Network across the Black Country.

Policy TRAN4 could also be further expanded upon in terms of rail freight, through capturing further enhancements to the existing rail network which facilitate rail freight growth into and through the Black Country including network capacity and capability upgrades to allow more frequent, longer and heavier trains on key domestic and deep sea port routes.