Policy Area E - The Black Country Transport Network

Bromsgrove District Council Response to the Black Country Core Strategy Issues and Options Report September 2017

1 Thank you for the opportunity to comment on Black Country Core Strategy Issues and Options Report, the below comments at this stage represents an officer response. Due to the timescales for consultation, there have not been any appropriate Council meetings for this response to be considered formally. This process will take place in October and should any amendments be required as a result of the formal consideration by Bromsgrove District Council we will advise you in due course.

2 At this early stage in the plan making process, the issues and option presented are viewed as a sensible approach to what is a substantial task of reviewing the existing Core Strategy. Whilst in principle partially reviewing the plan as opposed to a wholescale rewrite would appear to be a pragmatic. The introduction of substantial site allocations on land currently allocated as green belt into the process, may necessitate a more substantial review further down the line, should this be the view of BDC the Council will respond appropriately on this point in due course.

A number of more focused comments have been prepared relating to the key issues / sections of the report which are detailed below.

Key Issue 2 - Meeting the housing needs of a growing population.

3 The housing needs of the Black Country as presented under Key Issue 2 is clearly a big challenged which the plan is addressing positively. The Council accepts that a detailed piece of evidence has been presented in terms of the objectively assessed housing need, and at this stage has no reason to doubt the overall figure of 78,190. Recognition of the ongoing work being undertaken at the HMA level is welcomed, and BDC will continue to work alongside all HMA authorities in an effort to fully understand the needs of the Market area and the options for distributing growth. The 3000 houses which the Black Country Authorities have agreed to test is in principle supported. The statement at 3.19 of the report is significant and BDC agree that all the figures surrounding the housing requirement of the plan need to be tested on an ongoing basis as the plan evolves and more evidence becomes available.

Key Issue 3 - Supporting a resurgent economy

4 It is important that the Black Country continues to play its role in the economic prosperity of the region. The requirement of 800ha of employment land over the plan period would appear to maintain a flexible supply of land to cater for a wide range of needs. Acknowledging that the plan already envisages some existing employment land will be lost to housing, it is key that the best employment opportunities are safeguarded. If there are further opportunities for employment land to be released for other uses to minimise greenfield development then they must be considered favourably if appropriate.

Key Issue 6 - Reviewing the role and extent of the green belt

5 As the green belt in the Black Country has not been fully reviewed for approximately 40 years it is key that this work is now undertaken thoroughly. The Council agrees that any sites released from the green belt should be done in the context of the Core Strategy, and not left for other development plans to try and achieve. This is especially important if land outside of the Black Country area is going to be required. For any other authority to agree to take any additional development, the commitment to releasing land from the green belt in the Black Country needs to be enshrined in this plan. This commitment needs to be supported by clear policies which prioritise delivery of sites within the Black Country, before any land in neighbouring authorities is developed.

Key Issue 9 - Working effectively with Neighbours

6 The Council has successfully worked with the Black Country authorities over a large number of years. We look forward to continuing this approach both through the Strategic Housing Needs Study, and also ongoing liaison through the Duty to Cooperate, we would welcome the opportunity to discuss this response at the earliest opportunity.

Section 4. Reviewing the Strategy to Meet New Challenges and Opportunities.

7 This section of the issues and options report is seen as the most important by the Council, decisions made under this heading will have far reaching and long term effect for people, the environment, and the economy both within the Black Country and also beyond its boundaries. The 8 growth options identified on table 2 will all have differing implications and opportunities, some of which could have direct impacts on Bromsgrove District. The Council is not objecting to growth in principle, indeed it will shortly be embarking on a review of its recently adopted plan, including releasing land from the green belt. At this stage the Council is not able to form any definitive views on the options as they are presented. It would seem that all the options in one form or another could involve land being required outside of the Black Country and possibly in Bromsgrove District.

8 The Council would welcome the opportunity to explore these options further; once more information is available as a result of the call for sites process. Understanding what land is being proposed within, and on the periphery of the Black Country is important to begin to assess if any areas being put forward will have an impact on the District, in both positive and negative terms. Options need to be considered holistically in the context of the Core Strategy and the functions and purposes of the green belt around the Black Country. They must also be considered in the context of any emerging review of the Bromsgrove plan. If land is proposed to be released in the areas of Black Country near Bromsgrove or vice versa, full consideration must be given to ascertain if there are approaches which can complement both authorities plans, and bring benefits to both areas.

Policy Area E

9 Transport infrastructure both existing and new is vital to the success of the Core Strategy, the road links between Bromsgrove and the Black Country are heavily used and in some instances congested. Recent disruption caused by work being undertaken on the M5 at Oldbury has highlighted how infrastructure issues north of the District have significant effects across Bromsgrove, this is especially relevant for transport networks and the motorways in particular.

10 The Council welcome the statement made at para 6.1.28 'following the issues and options stage further transport modelling will be undertaken to forecast the traffic impacts of the specified green belt scenarios, identify locations that may require further investigation regarding traffic impacts and identify the transport infrastructure requirements for any potential new green belt sites (including highway, public transport, walking & cycling routes).' It is our view that the location of development should, along with all the other evidence, be informed by the consideration of the results of highways modelling as described above, and modelling should not be used simply to identify the mitigation required from a pre chosen site.

11 Bromsgrove DC has been working closely with Worcestershire County Council in response to the Worcestershire Local Transport Plan 4 to begin the preparation of a transport strategy for the north Worcestershire area. As part of this strategy the links and journeys by all modes, between north Worcestershire and the Black Country, and also those that pass through north Worcestershire will need to be understood. Following on from that the implications of range of development scenarios will need to be tested to inform final choices about development locations. We would welcome the opportunity to discuss this further with the Black Country. We would like to ensure that the tools that are available to assess the transport implications of developments some of which may have wider implications that just in one local authority area are used to the fullest, to ensure sustainable development patterns.

BDC Strategic Planning
6.9.17

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

The Black Country Core Strategy Issues & Options consultation report (the "Issues & Options") recognises that the Black Country is potentially unable to meet housing and employment land needs within its own boundaries. The Issues and Options notes the potential for some growth to be exported within the wider Greater Birmingham and Black Country Housing Market Area, which includes Bromsgrove district and Redditch borough. However, the issues and options gives little detail of any proposed growth outside the Black Country, and there seems to be little consideration of the impact this could have on neighbouring authorities, including the county and districts of Worcestershire.
The potential for growth in neighbouring local authority areas is alluded to, and the call for sites extends to those authorities adjoining the Black Country. We are concerned, however, that no reference is made to the impacts on infrastructure -particularly roads and education - that could arise from such growth. There are known areas of congestion on key transport routes in and around north Worcestershire, including at Hagley, at junctions 3 and 4 of the M5, and at junction 1 of the M42. AQMAs exist at Hagley and M42 J1, making these locations particularly sensitive to additional vehicle emissions. Capacity enhancements and solutions to traffic congestion could be very expensive and delivery would require a successful growth fund bid as well as developer contributions. More detaiI on such schemes cannot be known until modelling has been undertaken.
We support the proposals to invest in rail, which provides opportunities for growth, subject to agreed investment. WCC has strategic plans to increase rail accessibility and frequency to Birmingham, Kidderminster, London and Worcester.
Apart from private sector investment, the main potential sources of funding referred to are the Black Country LEP and West Midlands Combined Authority (WMCA), and we remind the Black Country authorities that WCC is not a member of the WMCA. This is a particular concern given the indicative viability of the plan, which suggests that future growth may need to be supported by external funding as it is unlikely that sufficient funding can be achieved through developer contributions.
We also have concerns that some areas adjacent to the Black Country that may be potential locations to accommodate Black Country growth may also be areas of interest to Birmingham City Council in meeting Birmingham's unallocated housing need. Dialogue needs to take place between Birmingham and the Black Country authorities, and also between the Black Country authorities, WCC, and relevant Worcestershire district councils, to identify areas of potential. It is important to ensure that proposals comply with the districts' visions for their future employment and housing growth.
We recognise the need for a Green Belt review, and would appreciate the opportunity to input into this as a neighbouring authority.

see attachment

The role of public health is to improve the health of our residents, prevent risks to public health and reduce health inequalities to help people live longer and healthier lives.
Public health works to improve the health and wellbeing of our communities by identifying the risks that affect different people, in different places, at different stages of life, and finding the best way to minimise them.
By working with external agencies and local communities we aim to:
* Keep people well
* Prevent people that are showing the early signs of poor health from becoming ill
* Improve the quality of life of those affected by ill health
Walsall is one of the 20% most deprived districts/unitary authorities in England and about 30% (17,000) of children live in low income families. Life expectancy for both men and women is lower than the England average.
Life expectancy is 10.5 years lower for men and 6.4 years lower for women in the most deprived areas of Walsall than in the least deprived areas. In Year 6, 25.5% (833) of children are classified as obese, worse than the average for England. Levels of teenage pregnancy, GCSE attainment are worse than the England average. Estimated levels of adult obesity and physical activity are worse than the England average.

The Health Foundation states that as little as 10% of the population's health and wellbeing is linked to access to Health Care. The population's health and wellbeing is influenced by a wide range of other factors including housing, transport, employment, green space, where we live.
The review of the Black Country Core Strategy provides real opportunities to improve the health and wellbeing of the population of Walsall and the below details the response from Walsall Council Public Health to this consultation.
The review document is quite a difficult document to navigate. It is long, not very user friendly and includes a large amount of jargon. The document includes a lot of questions, many of which are quite specific and make it difficult to respond to directly. Our comments as such, while not directly answering all of these, do provide information that will cover more generally some of the questions in each of the sections to follow:
A. Health and Wellbeing
PHE Spatial Planning for Health, an evidence resource for planning and designing healthier places, 2017 identifies five aspects of the built and natural environment as the main characteristics that can be influenced by local planning policy:
* neighbourhood design
* housing
* healthier food
* natural and sustainable environment
* transport
Many of the above are covered within this strategy.
In addition, the health and wellbeing of the local population can also have a huge impact on a local area. From an economic perspective a healthy population will have a reduced need for acute and long term health and social care services and will also be more likely to contribute to an active workforce - with improved productivity and less sickness absence.
Health and Wellbeing is not considered as a separate policy in the current Black Country Core Strategy. Therefore, as part of this review health and wellbeing should be given its own policy and be embedded into the other strategy policies.
Moving forward we would like to see:
* Further acknowledgement of the wider determinants of health
* Needs assessments that give due consideration to the health needs and demographics of the local area for example, the local Joint Strategic Needs Assessment (JSNA)
* Design standards that promote healthy lifestyles and environments across the life course. This should include 'lifetime neighbourhoods; identification of an ideal high street retail offer; consideration to fully pedestrianzing town centres; sustainable transport and green infrastructure networks
* Ensure potential health impacts are considered through a Health Impact Assessment that includes involvement from the Public Health team

B. Creating Sustainable Communities in the Black Country
Housing should aim towards 'lifetime neighbourhoods'. Rather than have separate accessibility standards, housing needs to consider the life course approach and be accessible to people of all ages. It also needs to be broader than just accessibility, for example, well-connected and walkable and design standards that promote healthy lifestyles and environments, considering the Ten Principles of Active Design (2015): Activity for all; walkable Communities; Connected walking and cycling routes; co-location of community facilities; network of multifunctional open space; High quality streets and spaces; appropriate infrastructure; active buildings management , maintenance; monitoring & evaluation; activity, promotion and local champions.
The housing plan needs to take into account any additional demand on associated local amenities of education, health, transport and leisure facilities. The needs assessment should be sensitive to changing local demographics e.g. extended family occupancy, Eastern European migration and multiple occupancy, which has a particular disproportionate impact upon local faith specific schools and local parking/transport. The plan should attend to the needs of marginalised groups and their specific needs e.g. single adults, young people, people with disabilities and the frail and elderly as well as the hidden homeless. Attention should be given to the travellers/gypsy and showman plans and how this relates to the challenge of unauthorised encampments.
There is a plan to increase high density housing allocation in Walsall which is a particular challenge.
A Health Impact Assessment should be undertaken for any major housing developments with the support of Public Health.

C. The Black Country Economy
Setting targets for employment land is important however, this needs to have the balance particularly in terms of where the Greenbelt is located. For example, much of the Greenbelt is located in the East of the borough and is difficult to access for people in more deprived areas in the West. This is an opportunity to link with the transport policies to look at how this can be addressed.
Building social housing, as part of housing developments, planned for the Greenbelt could also help address this.
Priority sectors require highly trained staff. Does the local population have these skills or will the new development create 'commuter workers' from other areas who invest very little to the local economy? Unemployment in Walsall is higher than the England average. Training needs to be made available for the local population if local people are going to be able to access these jobs. This needs to include a focus on those from the most deprived areas of the borough.
Design considerations to promote healthy living also need to be considered in building developments.
D. The Black Country Centres
Whilst the importance of business rates is noted, there is a need for this to be balanced with a more mixed retail offer in Walsall town centre. PHE has found that hot food takeaways per 100,000 population in Walsall is higher than the England average, 93.7 per 100,000 compared to 78.3 per 100,000. In 2014 in Walsall, there were 654 licensed premises, which is 312 per 100,000 population (aged 18+) .
There is an opportunity to develop a profile of the retail offer currently available in Walsall for different categories of outlets, and what the ideal profile might be. The Royal Society of Public Health: Health on the High Street (2015) recommends measures to include:
* Local authorities to use planning powers to prevent the proliferation of betting shops, payday lenders and fast food outlets
* Public health criteria to be a condition of licensing for all types of businesses
* A limit of 5% of each type of business on a high street in order to avoid oversaturation and provide affordable choice.
Consideration should be given to fully pedestrian town centres with more sustainable forms of transport and design giving full consideration to accessibility for all e.g. people with disabilities. This will improve the health and wellbeing of the population and community safety.
Consideration should be given to community safety partnership data to avoid the adverse effects of town centre planning (proliferation of issues associated with substance misuse and street workers).
E. The Black Country Transport Network
There is strong evidence that motorised road transport provides clear benefits to society and improving the road networks across the region should provide wider economic benefits, however there is a potential cost to society (Public Health England, 2016 ). Increased car journeys can lead to a rise in the disease burden due to reduced physical activity and in addition it is expected that there will be an increase in road accidents, air pollution, noise and even reduced social cohesion and increased social isolation (Public Health England, 2016 ).
Walking and cycling should be the easiest and preferred option and the strategy should give consideration to inverting the hierarchy of transport e.g. walking, cycling, public transport car, share and private car. In doing so it is reflective that investment in walking and cycling infrastructure and behaviour change programmes can deliver low cost, high-value dividends for the transport system, the whole economy as well as individual benefits. In addition to support, an increase in the number of people walking and cycling, community protection and safety should be considered within the strategy. Small improvements can make a difference to encouraging people to be active including good street lighting or improved road crossings.
In relation to health inequalities those who live in more deprived areas tend to travel less than those in more affluent areas but bear the greatest burden of other peoples travel (Public Health England, 2015). It is important that the core strategy does not increase unfairness in communities (Sustainable Development Commission, 2011).
There is a requirement to ensure good access to services in the most sustainable way possible. It is important that vulnerable groups including individuals with disabilities and older people including those with dementia are consulted in the planning and development of their communities, as they can often provide local solutions that address areas of potential conflict. The street environment and transport interchanges need to be designed to meet the needs of individuals - including an interlinking of the different modes of transport.
The strategy details improvements to public transport but clarification is required that this means that there will be less cars on the road which should improve air quality and see a reduction in the number of accidents. Public transport needs to be easy and accessible for all to use but it is important that the costs are not passed down to the consumer as this could be a barrier to usage. It also needs to be incentivised to use or made easier and more accessible for all to use and more cost effective.
There is a growing body of evidence that is supportive of 20mph speed limits (Cairns, J et al 2014 ) and repeated national surveys (Department of Transport ) demonstrates that there is strong public support for these in residential streets.
Will the detailed improvement to freight access include measures around air quality/ noise quality? This should improve economic growth and the flow of lorries on the motorway.

Consideration should be given to;
* Closing streets to allow active play for children and for residents to come together as a community. Areas outside of the Black Country (Hackney etc) have successfully demonstrated this approach.

* Impact of electric car policies (new government legislation)

* Car Share

* Community infrastructure levy - reinvestment back into communities to encourage active participation.

The Black Country Environment
We support the principles of a Garden City and recommend that these are applied. These are: sustainable transport and green infrastructure networks; bio-diversity gains; carbon emission reductions and climate change resilience.
Design quality (including space and accessibility) needs to be considered as above, housing needs to consider the life course approach and be accessible to people of all ages.
Walsall canals are an asset which can be developed to enhance active travel within the area. We would not support the removal of the reference made to canal projects. We consider canals to be important in contributing to emotional health and wellbeing.
We support the proposed changes relating to open space, sport and recreation but we believe the policy needs additional criteria to be added to provide sufficient protection form development of open space.
It states that development that reduces open space will be resisted and that increases will be encouraged. We suggest the use of the Natural England Access to Natural Greenspace Standard to provide a quantifiable measure of the importance of particular areas of open space is required. Further clarification on what constitutes open space is needed as the policy does not specify publically accessible open space.
Air Quality
West Midlands has the poorest air quality outside of London.
We support the proposed changes. ENV08 also needs to be updated to reflect:
* West Midlands Pollution Group (which in-turn works within the framework of the Central England Environmental Protection Group).
* West Midlands Combined Authority (CA), (including Transport for West Midlands in respect of a range of issues that encompasses proposals for Clean Air Zones and the uptake of Low Emission / Ultra-Low Emission Vehicles).
Walsall Council additionally works specifically with the Black Country councils, and has produced the Black Country NO2 road emission concentrations model. This is a workstream that is subject to on-going review as long as resources permit, and an updated model output is scheduled to be released later this year. Other Black Country work streams include the Black Country Ultra-Low Emissions Vehicle Strategy and the Black Country Air Quality Supplementary Planning Document.