Comment

Draft Black Country Plan

Representation ID: 45902

Received: 11/10/2021

Respondent: Transport for West Midlands

Representation Summary:

Whilst we don’t disagree with any of the current policies presented in this chapter, we consider that this policy together with several others including (Transport etc.) need to be much stronger in terms of being clear on the role spatial planning and its relationship with transport demand and travel behaviours plays in achieving net zero and the decarbonization of the transport system, through reducing the wider impacts of travel, including the energy demands of transport.

However, this Climate Change chapter is very much about mitigation and adaptation, as opposed to preventative action, and to fully achieve net zero by 2041 across our region, we must do this at scale and pace.

The WMCA is fully committed to its own WM2041 carbon ambition which means using cars less together with a mix of the following to take place:
• Reductions in the frequency of travel – consolidation of trips or replacement of travel with use of information and communication technologies;
• Changes to where people travel to/from – making shorter journeys and/or to places that are more
easily accessed and served by more sustainable modes of travel; and
• Changing the vehicles used to travel – modal shift to more sustainable modes such as public transport and walking and cycling and switching to personal vehicles that require less energy to use such as smaller cars, personal light vehicles, and micromobility.

Based on the above, under Policy CC1 (1b) it is important that all development, be designed to support rapid decarbonization of transport, and where it may generate additional trips, it should demonstrate that their impact overall, does not result in additional carbon emissions. When the transport modelling work is complete and shared with TfWM, a greater understanding of the true impact of the plan proposals as well as the extent of net carbon increases from transport will hopefully be demonstrated.