Reviewing the Spatial Strategy

Dear Helen

BLACK COUNTRY CORE STRATEGY ISSUES & OPTIONS CONSULTATION

Thank you for forwarding me details of the above referenced consultation. Highways England ('we') are responsible for the operation and maintenance of the Strategic Road Network (SRN) in England. The network includes all major motorways and trunk roads.

The M5 and M6 motorways which form part of the Birmingham Motorway 'Box' are sections of the SRN in the area covered by the Black Country Joint Core Strategy.

Highways England has undertaken a review of the consultation material in order to consider the potential implications arising for the SRN from the revised Core Strategy.

The consultation document asks a significant number of questions, only some of which are directly relevant to our remit.

Question 1 of the consultation considers the approach to the review of the plan. Highways England support the proposed approach to provide a partial review of the 2011 plan such that it maintains in general, the existing 'two tier' document approach to setting the spatial portrait of the area. We note however that the Core Strategy document sets out that "it may be necessary for the Core Strategy to include allocations of strategic sites". We consider that such an approach is essential for the consideration of any new strategic growth sites not already considered by the existing plan.

Such sites will often require the delivery of significant transport infrastructure, which takes time and resources as well as good co-ordination between different stakeholders to deliver. To ensure the cumulative implications of such sites are properly considered it is vital that the Core Strategy provides as much clarity as is possible on the location and scale of proposed strategic site allocations at the submission stage of the plan so that the strategic transport implications of such development can be determined and mitigation strategies agreed.

Question 5 of the consultation considers the need for a Green Belt review. Highways England supports the approach to the Black Country Green Belt review subject to the principle that existing or new policies seek to continue to maximise the reuse of brownfield land as the starting point for site allocation policy. Such a sequential approach is likely to provide the best opportunity to reduce the transport implications of development.

Evidence Base
We have considered the proposed evidence base set out in Section 3 table 1 of the consultation document and have the following observations:

We support the principle that the Greater Birmingham and Black Country Housing Market Area (HMA) Strategic Growth Study and a Black Country Green Belt Review should form the key evidence base for any new strategic land allocations considered under the Black Country Core Strategy. We note, however, that the Infrastructure and Transport evidence bases as currently outlined lack precision as to what the terms of reference of the Infrastructure Studies and Transport Impacts and Accessibility Planning Study will include.

As the Highway Authority for the SRN it is important that Highways England is consulted on the terms of reference for these studies to confirm what further involvement will be necessary so that the evidence base suitably considers the implications of development upon the SRN. In particular, we note that the Highways England Route Strategies (published in March 2017) includes the relevant evidence on the challenges affecting our network. The relevant Route Strategy reports comprise:

* London to Scotland West: (includes M5 and M6 corridors)
* Midlands to Wales and Gloucestershire: (includes M54 corridor)

Further emphasis should also be put on upcoming major regional study projects including that being developed by Midlands Connect which is considering strategic issues on the Birmingham Motorway Box.

Connectivity
A major issue concerning Highways England with regard to the Core Strategy is the connectivity of the Black Country and any future infrastructural challenges arising from the Plan. Connectivity is identified as a key issue within the Core Strategy consultation, however, at this stage new issues are not explored in detail and we note no decisions on additional transport or land use policies have been taken. Matters relating to the spatial strategy are considered and these have a strong inter-relationship to connectivity needs. Further engagement with Highways England on connectivity issues will be necessary as the plan develops.

Spatial Strategy
We have reviewed the approaches considered with regard to the setting of a new spatial strategy for the Black County and our comments on the two stage approach set out in the consultation can be found below. With regard to our responsibility for the operation of the SRN, these comments therefore relate to the transport implications of the Options.

Stage 1 (Questions 10, 11a and 11b) - It is our view that the transport implications of Option 1A of the consultation are likely to provide continuity of the existing known transport issues arising from the 2011 Core Strategy with further issues arising incrementally from issues arising from Stage 2. Option 1B would give rise to a different set of transportation implications than existing policies. This approach could have either net positive or net negative implications for overall traffic flow on the SRN depending on how the policy is implemented but not enough information is available on the approach to determine this question at this time.

Should Policy 1B be implemented it may be capable of providing beneficial transport implications by seeking to maximise opportunities to place higher density development in locations benefiting from access to high quality sustainable transport networks. It may also provide an opportunity to relocate inappropriately sited existing lower density employment development (such as B8 warehousing) out of inappropriate locations. In implementing such an approach a careful balance would need to be struck to ensure the approach does not result in an excess level of 'out commuting' from existing urban areas in the Black Country to greenfield sites on the periphery of the West Midlands conurbation.

Stage 2 - (Questions 12a-14) - In transport terms we consider that Spatial Strategy Option H2 to provide an approach to housing in the Green Belt via the provision of Sustainable Urban Extensions (SUEs) to be preferable to H1. H1 may result in an uncoordinated approach to the provision of the necessary transport infrastructure and higher levels of reliance upon travel via private cars.
Option H2 is likely to be capable of maximising access to sustainable transport via the co-location of development with rail stations or other sustainable transport infrastructure. This is likely to be the best way that the spatial strategy can maximise opportunities to reduce the traffic implications of development. Highways England therefore supports the H2 approach insofar that it is identified to be compatible with the most sustainable outcomes identified from Stage 1.
Stage 2 - (Questions 16-20) - We have considered the transport implications of Spatial options E1, E2, E3 and E4 with regard the provision of land for employment outside of the existing urban areas. Site specific consideration are likely to be highly relevant to any sites considered under such broad strategies and it is not possible for us to identify preferred options based upon the level of evidence produced to date.

On the basis of the current information available we would note the following points:

* Option E3 appears to offer the greatest opportunities to support the provision of new sustainable transport infrastructure in Green Belt locations. This potentially could be delivered in combination with allocations considered under option H2 which is likely to provide the maximum opportunity within Greenfield sites. Option E1 is also likely to provide some opportunity to maximise the use of existing infrastructure. However, it carries site specific risks that some locations may add to existing highway capacity constraints; conversely other sites might add critical mass to ensure support for investment in sustainable transport infrastructure serving new and existing development is forthcoming.

* In transport terms option E2 appears most challenging to achieve transport sustainability as free standing sites have no existing population or infrastructure to support them. Any such sites would need careful consideration of the wider transport implications and be selected carefully on their own merits.

* Option E4 proposes to consider the export employment growth to neighbouring areas. This could consider how further employment growth in Birmingham and improved transport links to the Black Country might complement that Authority's housing needs which may need to be addressed within the Black Country. For other less accessible locations, which do not benefit from strong sustainable transport links to the Black Country, we note the risk that Option E4 could give rise to a high level of out commuting traffic via single occupancy private vehicles trips. If Option E4 is adopted then it should follow similar principles to option E2 in site selection to reduce the transport implications of development.

At this stage we have considered the issues likely to arise from the Black Country Core Strategy review but it is not possible to fully determine how these issues will result in specific transport implications for our network. As spatial options are developed we would encourage further engagement with us so that that the implications of the leading options can be considered further by us prior to the next stage of the plan's development. In particular, we would anticipate that effective dialogue over development of the evidence base as it relates to transport will be forthcoming.

Please do not hesitate to contact me if you require any more information or clarification.

Yours sincerely

Patricia Dray
OD Midlands
Email: Patricia.Dray@HighwaysEngland.co.uk

Cc: Catherine Townend (Highways England)
Matthew Taylor (Highways England)
Chris Cox (Systra)

Thank you for the opportunity to respond to the Black Country Core Strategy Issues and Options Report.

As Stafford Borough is a neighbouring authority to South Staffordshire District and Cannock Chase District a number of the Spatial Options within the Report could have development and infrastructure implications for the Borough, although it is worth noting that Stafford Borough is not within the Greater Birmingham and Black Country Housing Market Area, nor the Greater Birmingham & Solihull LEP or Black Country LEP areas. In particular the Habitat Regulations Assessment of future housing growth in the Black Country may need to be addressed in order to provide mitigation measures for the Cannock Chase Special Area of Conservation together with implications for the wider Cannock Chase Area of Outstanding Natural Beauty.

Based on the Strategic Challenges and Opportunities, the Borough Council is generally supportive of the vision, principles, spatial objectives and strategic policies within the Issues and Options document. However it is important to ensure that a balanced approach takes place between the development requirements of neighbouring areas and the focus for new infrastructure, housing and employment growth within the Black Country area. Clearly it is important that the local population needs within the Black Country are accommodated by the delivery of new developments to reduce out-migration and pressure on the strategic transport network.

In terms of the approach for accommodating growth it is noted that the Black Country are continuing the role of the Growth Network and Regeneration Corridors from the adopted Core Strategy. However this will require the delivery of brownfield sites across the Black Country which experience a range of infrastructure, historic contamination and viability constraints impeding the level of development achievable. Therefore it would appear that options associated with Stage 2 including Green Belt release within the Black Country, either through rounding off or Sustainable Urban Extensions will be required to meet housing and employment development requirements. The implications of these Stage 2 options could be a significant net outflow of residents and economic activity away from the Black Country's Strategic Centres towards other areas, putting additional pressure on transport links.

It is noted that within the Spatial Options is a section on 'meeting housing needs outside the Black Country', firstly in neighbouring authorities or secondly exported outside of the Housing Market Area. Notwithstanding the impact on the Black Country through the loss of economically active population, both of these 'export' options could have implications for Stafford Borough. If additional housing growth is accepted by South Staffordshire District there is the potential for non Green Belt areas south of Stafford, but in South Staffordshire District, being considered through a Local Plan Review process leading to infrastructure pressures on the County Town of Stafford. A recent example of this scenario has been highlighted by a planning application for 200 new homes immediately adjacent to Wildwood, Stafford but within South Staffordshire District. From the employment perspective the proposed Strategic Rail Freight Interchange development in South Staffordshire District is being promoted in order to provide for the Black Country's unmet logistic needs, which demonstrates the challenge of delivering suitable sites within the Black Country area and the outward movement of economically active people.

The adopted Plan for Stafford Borough (June 2014) focuses the majority of new housing and employment provision at Stafford Town, without releasing Green Belt areas, and a number of significant development sites are now being delivered. As you may be aware the Borough Council has recently initiated a Local Plan Review to set out the future development strategy beyond the adopted Plan period of 2031. Therefore if it is considered necessary to deliver development in other areas the Borough Council would welcome an opportunity to discuss the implications of this approach in more detail, to ensure the infrastructure implications are considered in balance with achieving housing and employment needs across a wider area.

Thank you for the opportunity to respond to the Black Country Core Strategy Issues and Options Report.

As Stafford Borough is a neighbouring authority to South Staffordshire District and Cannock Chase District a number of the Spatial Options within the Report could have development and infrastructure implications for the Borough, although it is worth noting that Stafford Borough is not within the Greater Birmingham and Black Country Housing Market Area, nor the Greater Birmingham & Solihull LEP or Black Country LEP areas. In particular the Habitat Regulations Assessment of future housing growth in the Black Country may need to be addressed in order to provide mitigation measures for the Cannock Chase Special Area of Conservation together with implications for the wider Cannock Chase Area of Outstanding Natural Beauty.

Based on the Strategic Challenges and Opportunities, the Borough Council is generally supportive of the vision, principles, spatial objectives and strategic policies within the Issues and Options document. However it is important to ensure that a balanced approach takes place between the development requirements of neighbouring areas and the focus for new infrastructure, housing and employment growth within the Black Country area. Clearly it is important that the local population needs within the Black Country are accommodated by the delivery of new developments to reduce out-migration and pressure on the strategic transport network.

In terms of the approach for accommodating growth it is noted that the Black Country are continuing the role of the Growth Network and Regeneration Corridors from the adopted Core Strategy. However this will require the delivery of brownfield sites across the Black Country which experience a range of infrastructure, historic contamination and viability constraints impeding the level of development achievable. Therefore it would appear that options associated with Stage 2 including Green Belt release within the Black Country, either through rounding off or Sustainable Urban Extensions will be required to meet housing and employment development requirements. The implications of these Stage 2 options could be a significant net outflow of residents and economic activity away from the Black Country's Strategic Centres towards other areas, putting additional pressure on transport links.

It is noted that within the Spatial Options is a section on 'meeting housing needs outside the Black Country', firstly in neighbouring authorities or secondly exported outside of the Housing Market Area. Notwithstanding the impact on the Black Country through the loss of economically active population, both of these 'export' options could have implications for Stafford Borough. If additional housing growth is accepted by South Staffordshire District there is the potential for non Green Belt areas south of Stafford, but in South Staffordshire District, being considered through a Local Plan Review process leading to infrastructure pressures on the County Town of Stafford. A recent example of this scenario has been highlighted by a planning application for 200 new homes immediately adjacent to Wildwood, Stafford but within South Staffordshire District. From the employment perspective the proposed Strategic Rail Freight Interchange development in South Staffordshire District is being promoted in order to provide for the Black Country's unmet logistic needs, which demonstrates the challenge of delivering suitable sites within the Black Country area and the outward movement of economically active people.

The adopted Plan for Stafford Borough (June 2014) focuses the majority of new housing and employment provision at Stafford Town, without releasing Green Belt areas, and a number of significant development sites are now being delivered. As you may be aware the Borough Council has recently initiated a Local Plan Review to set out the future development strategy beyond the adopted Plan period of 2031. Therefore if it is considered necessary to deliver development in other areas the Borough Council would welcome an opportunity to discuss the implications of this approach in more detail, to ensure the infrastructure implications are considered in balance with achieving housing and employment needs across a wider area.

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.