Comment

Draft Black Country Plan

Representation ID: 45903

Received: 11/10/2021

Respondent: Transport for West Midlands

Representation Summary:

Under policy CC4 Air Quality, paragraph 10.179 should also be expanded to include the following text: “This revised version will need to take into account the current Environment Bill and it’s requirement for new UK targets, to be set by October 2022, for annual average levels of PM 2.5 in ambient air, and for population exposure reduction to PM 2.5. The University of Birmingham-led WM-Air Project, which is supported by West Midlands local authorities and WMCA, will then help inform the development of the new Black Country Air Quality Supplementary Planning Guidance document”

Furthermore, under the Strategic Approach (point 1a) the policy should include public transport and read “the integration of cycling, walking, public transport and electric charging points as part of their transport provision”. Also point 1b should include walking and cycling and read “promoting and supporting (including through continued joint working with authorities outside the Black Country) a modal shift from private motorised vehicles to use of clean, fast and accessible public transport alternatives such as rail, the Metro and bus transport networks and cycling and walking”.

In summary, greater acknowledgement of decarbonizing the transport system is required in this chapter, through ensuring new developments do not result in additional trips and carbon emissions, through using far less energy intensive personal vehicles and more sustainable modes and ensuring our land use policies result in people travelling far less and over shorter distances. Aligning this chapter with that of the transport chapter is therefore imperative, to demonstrate the links transport plays in tackling the climate emergency.