Comment

Representation ID: 45900

Received: 11/10/2021

Respondent: Transport for West Midlands

TfWM has responsibility for Park and Ride sites, certain electric vehicle charging infrastructure and some cycle parking provision. As part of wider policy and demand management measures, to restrain car usage and increase sustainable modes, we see car parking management measures being vital.

The current WM LTP4, Movement for Growth sets out a need for a metropolitan parking strategy to balance the role of car access to centres to support economic vitality, whilst promoting the use of sustainable travel. This is to ensure that private car volumes are not at such levels where the dominance of the car detracts from the quality of our centres.

Based on this, we welcome many of the points made under policy TRAN7, however the importance of good quality parking needs to be presented too. From TfWM’s LTP evidence review into parking, the ‘whole quality parking experience’ including how parking interconnects with other transport modes is seen as extremely important. And where ‘mobility hub’ style options are available with pop up shops, distribution lockers, ZEV charging opportunities and food outlets alongside standard car parks and sustainable transport options, these are welcomed, and have helped reduced the impact of parking in other towns and cities.

From our LTP evidence base research, we also know that only 20% of trips into centres are for commuting purposes with the remainder being for retail and leisure. There is also limited evidence to suggest that parking charges act as a deterrent to shopping trips, and its good quality pedestrian measures and investment in traffic reduction and public realm which increases retail footfall and makes the greatest impact on local high street economies, and we would be happy to share our evidence in this area, to help shape further the parking policies within the plan.

The NPPF also echoes this by stating “that local authorities should consider an area’s accessibility, type, mix and use of development, availability of public transport, local car ownership levels … when setting local parking standards”.

Based on this, paragraph 9.61 should be altered to read: “The management of car parking is fundamental to achieving the Vision for sustainable communities, environmental transformation and economic prosperity. It also has a key role in helping to reduce the overall level of private vehicle trips with obvious benefits for congestion, road safety, air quality and carbon emissions”.

Under policy TRAN7 1a, concerning parking measures between centres, we feel the decision to not include Brierley Hill (Merry Hill) within the parking policy for charging across strategic centres is a serious omission. It should be noted that the WMCA (under written by Dudley MBC and the other West Midlands constituent authorities) are investing many millions of pounds into improving public transport connectivity across the Black Country, including the Wednesbury to Brierley Hill Midland Metro Extension. To support this investment, substantial funding has been raised by loans which are linked to increased use of the Midland Metro (as part of its extension). This policy as drafted, has potential to create challenges with regards to the jointly targeted strategic outcomes of increased public transport usage as an alternative to single occupancy car usage.

Under more general comments now, there is no policy reference to parking facility / kerb side management requirements for freight, servicing and logistics, for ZEV charging points, for pick-up/drop off points for taxis, car club schemes, coaches and bus layover points, for powered two wheelers and cycle parking or parking for disabled people. Hence, policy TRAN7 could be expanded upon, to cover wider parking matters including:
• Promoting car free developments in those most accessible locations where excellent public transport is available.
• Introducing permit parking schemes for new developments.
• Ensuring adequate parking provision for disabled car drivers and passengers.
• Full consideration of ZEV charging infrastructure and parking, together with spaces for ZEV car clubs
– covering both off street and on street public parking provision.
• The need for all future stations/interchanges/mobility hubs to be designed with restrictive car parking and full promotion of sustainable options for onward journeys, including cycle hire facilities/bus connections.
• Incorporating secure and covered cycle parking to meet long-term demand from occupiers and visitors, in convenient locations to maximise usage, together with consideration of showers, changing facilities, lockers and bike hire scheme parking.
• Adequate provision of designated pick-up/drop-off points for taxis, demand-responsive transport services and car clubs etc.
• Adequate parking and docking facilities for escooters.
• Endorsing mobility credits as incentives to new residents to give up parking spaces, with usage of spaces being kept under review.
• Making appropriate parking provision for deliveries and servicing (including the requirement of Delivery and Servicing Plans for appropriate developments) to help meet road safety requirements, transport emissions and other environmental impact standards and reduce repeat deliveries.
• Promoting controlled parking zones around schools and early years’ settings.

In addition to the above bullet points, consideration should be given to further measures to help manage the overall demand for travel such as the expansion of Controlled Parking Zones, greater use of Traffic Regulation Orders and the role out of permit schemes.

Also where car parks are under-utilised, changes in land uses could be explored including replacing parking provision with mobility hubs, and be adapted to reflect demand, and we have seen this as a policy in other local plans across the region and beyond. Also, any policies which restrict the proliferation of ‘bomb site’ car parks on vacant land would further be welcomed.