2 The Black Country 2039: Spatial Vision, Strategic Objectives and Strategic Priorities

Object

Representation ID: 12890

Received: 11/10/2021

Respondent: Mr Barry Naylor

Housing/Environment
No to any further Housing Development There are already over 23,000 unoccupied Long term Housing not being used
No to any further Asphalt Surfaces/Roads that Damage The Environment
No to further Development that will Contribute to flooding Surface water run off or foul water. Drainage systems which are already struggling to cope.
No to any housing that impacts the NHS, GP Services The NHS is already in crisis
No to any further vehicle increase which will increase immissions and impact Air Quality
No Building on any Green area we need more green Areas not less
No to any Development that Damages the environment
No to any Developments that increases Schools or educational facilities
No to any Tarmac or Concrete Roads that will impact Climate change
Yes to climate consideration but no to these Destructive plans

Object

Representation ID: 13463

Received: 21/10/2021

Respondent: Mr Chris Sylvester

[No written submission, only an objection]

Comment

Representation ID: 14552

Received: 10/10/2021

Respondent: Alison Wilkes

2 The Black Country 2039
2.3 Figure 1 Relationship between Vision and Objectives (and throughout)
Comment: The built and natural environments are distinct and should be included as separate objectives/entities

Object

Representation ID: 16166

Received: 23/11/2021

Respondent: Mr Anthony Hook

Will the Draft Plan be amended in light of the Government’s pausing of its controversial planning reforms if subsequently there are any relevant revisions to their proposals?
Subsequently in the Prime Minister’s address to the Tory Party Conference on 6th October, as reported in The Daily Telegraph, he pledged that no homes should be built on green fields ‘as ministers abandoned their plans for an overhaul of planning proposals.’ If this is the case then the Draft Plan will require a major review and any proposals to redesignate green belt land for house building should be reversed and discontinued forthwith in accordance with the Government’s latest intentions.
The Draft Plan appears to be in direct conflict with a number of requirements of the National Planning Policy Framework and the Council’s own policy requirements and design principles, the latter two of which have presumably over time been approved by elected members as part of the democratic process.
Where is the evidence to support the assertion there are insufficient brownfield sites to satisfy the demand for new build housing in Walsall? Of the 13,344 new homes, more than half, 7133 (figure given from a laptop at drop in session on 1st October) or 5418 (identified in the Summary document) are proposed to be built on the green belt with a derisory claim this is only 8% of the Borough total. What is the comparable figure for brownfield sites?
The use of green belt sites is indefensible in that green open spaces, essential for agriculture, enjoyment and leisure purposes are lost while brownfield sites remain undeveloped, often contaminated, more likely to be derelict, neglected and an eyesore to the local residents. This approach does not and will not regenerate communities.
If green belt sites have to be used to satisfy demand when there is no viable alternative, which is difficult to accept or comprehend, why is it not possible to proritise those with no impact on existing residential housing for development?
Landowners offer/sell desirable land for development for personal greed, generally with total disregard for and to the detriment of local residents/communities and other wider environmental issues in the knowledge that developers prefer green belt land for obvious reasons and will pay a premium for it.
The Draft Plan places an unacceptable and unfair burden on the Aldridge/Brownhills area with 5,500 new houses out of a total of 7,100 proposed on the green belt for the whole Borough of Walsall. What is the percentage of green belt land being sacrificed in Aldridge/Brownhills?
Why cannot neighbouring rural counties/authorities which have far more green belt and open spaces accept or be required to accept more of the responsibility for new housing? What is the percentage of green belt and open space/density of housing for each neighbouring local authority? In the Black Country Walsall has the highest target for new build housing.

Object

Representation ID: 17771

Received: 10/10/2021

Respondent: Mrs Katie Turley

Objection to the Black Country Plan.

Date Sunday 10/10/2021

I have read and studied the Black Country Plan and I object to the proposals to build hundreds of homes on green belt land as part of the Black Country Plan.

There are many and varied reasons why I oppose these developments on our precious green belt land and I list them below:
Firstly I believe there is a flaw in the projections that underpin the plan. The projections come from the Office of National Statistics and are based on the average growth of the previous 20 years. The ONS stated that 86% of the growth in population in this period was largely due to free movement within the EU. We have now left the EU and free movement of populations has ceased. The Black Country Plan will be forcing us to build over precious green belt land for homes that are not needed!

There are many other reasons to be concerned and I list a few below.

1 Highways – our road infrastructure is already at capacity with long delays to journey times at pinch points along our high streets including, Kingswinford Sedgley, Wallheath and Wordsley to name a few. Building even more homes will severely add to this problem of congestion whilst increasing pollution and hence global warming as well as adding to the stress levels of commuters and also pedestrians.
2 Infrastructure – Schools, Hospitals, Dentists, Doctors GP surgeries are all creaking under the demands of the existing population. Adding thousands more homes will make the demands for those services rocket even higher!
3 Mental wellbeing – these precious Green areas help to give local people solace from the stresses and demands of our crowded and pressured lives. One adverse example is the proposal to build 24 homes on land off Viewfield Crescent Sedgley, means that on rare occasions of snowfall local children (and Adults) will be deprived of one of the few places they can use sledges due to the severe slope of the land.
4 Local wildlife, flora and fauna – we are being urged to plant more trees to help battle global warming, thses plans will result in the loss of hundreds of trees which will never be replaced!

Every attempt must be made to stop the ever increasing population explosion in our country nationally and locally, otherwise Britains “green and pleasant land” is doomed. As our representatives you must do everything in your power to protect every square inch of our precious Green Belt areas

Comment

Representation ID: 17830

Received: 01/10/2021

Respondent: Mr Kevin Grainger

Comments as follows:

1) This plan is extremely detailed and complicated and requires much study. I don't believe that it is being communicated in a clear and concise fashion to the general public. Perhaps this isn't easy, but this current presentation is detail heavy.... >
2) On what basis does central government determine that the Black County requires 76,000 new homes over the next 20 years - where is this perceived demand coming from?

3) My belief is that as urban areas we need as much green space and biodiversity as possible and also that we should NOT be building on greenfield sites.

4) There are recent covid accelerated trends eg more home working, which I am not convinced have been taken into account. This will lead to a need for less office space. This could be converted to living accomodation.

5) I would like to see a greater emphasis on creating accomodation in town centres above shops and converting existing structures for housing where possible. This willl greatly assist the development and safety in town centres and make use of what already exists. An example of what I would term "random destruction" is the recent complete demolition of the old cinema off Stourbridge ring road on the road up to Oldswinford. My belief is that this building had history and should have been re-purposed and cherished not demolished. Such "development" ie demolition robs an area of it's character.

Object

Representation ID: 17832

Received: 01/10/2021

Respondent: Mr Kevin Grainger

Comments as follows:

1) This plan is extremely detailed and complicated and requires much study. I don't believe that it is being communicated in a clear and concise fashion to the general public. Perhaps this isn't easy, but this current presentation is detail heavy.... >
2) On what basis does central government determine that the Black County requires 76,000 new homes over the next 20 years - where is this perceived demand coming from?

3) My belief is that as urban areas we need as much green space and biodiversity as possible and also that we should NOT be building on greenfield sites.

4) There are recent covid accelerated trends eg more home working, which I am not convinced have been taken into account. This will lead to a need for less office space. This could be converted to living accomodation.

5) I would like to see a greater emphasis on creating accomodation in town centres above shops and converting existing structures for housing where possible. This willl greatly assist the development and safety in town centres and make use of what already exists. An example of what I would term "random destruction" is the recent complete demolition of the old cinema off Stourbridge ring road on the road up to Oldswinford. My belief is that this building had history and should have been re-purposed and cherished not demolished. Such "development" ie demolition robs an area of it's character.

Comment

Representation ID: 18426

Received: 07/10/2021

Respondent: Richard Brooks

The following are vitally important policies:
Strategic Priority 2: To adapt to and minimise the impact of Climate Change…..vital if we are to survive.
Strategic Priority 11: To protect and enhance the natural environment, biodiversity, wildlife corridors geological resources, countryside, landscape…. Absolutely vital considering the serious decline in biodiversity we have.
Strategic Priority 10: To prioritise sustainable and active travel….vital to support SP1.
Strategic Priority 13: To manage waste….. – this needs to mention recycling where waste cannot be avoided.
Growth
There is much mentioning of growth when I thought we had realised we cannot keep growing for ever as resources are finite and therefore we should be looking for decline to a base level that is sustainable. There is also a need to give space back to wildlife for it to thrive. Population reduction is needed but slowly to reduce the effects of an increasing older population.
I suspect the plan is out of date as sustainability will need local centres enhanced with mixed development so people don’t need to travel far for facilities or work. Back to self-sufficient villages as much as possible.
Building on the Green Belt is contentious and this was created to form a green lung for the urban area. It must not be sacrificed to short term housing gain. I am also aware that some brownfield sites can become valuable for wildlife and provide greenery in the urban area.

Comment

Representation ID: 18891

Received: 25/09/2021

Respondent: Mr Richard Carter

ntroduction:
To someone who has lived in this country for an extended period of time with their eyes firmly open, it is apparent that, particularly when it comes to central and local government, the UK suffers from:
• An inability to apply common sense and to see the wood for the trees;
• An unfortunate propensity towards knee-jerk reaction, ill-conceived policies, lack of coherent strategies, taking no action where action is obviously required and taking action for completely the wrong reasons;
• Policies that appear to benefit the elite and the government rather than society as a whole.


The net result of this situation is that the UK now has a society that is rapidly deteriorating and becoming more and more dysfunctional, and filled with individuals who lack respect for themselves, others or for law and order, discipline and ambition and who, additionally, consider themselves and those in their immediate circle as being far more important than the rest of society.

Although the Covid-19 pandemic has revealed a number of extremely positive traits, it has also served to highlight the negativity that pervades society. For example, through:
• Panic buying.
• Not following social distancing guidelines.
• Finding excuses for not wearing masks in shops and enclosed spaces (one member of a family could conceivably be exempt, but not an entire family).
• Openly flouting lockdown measures.
• Generally denying that the pandemic exists.
• Worsening levels of already deplorable customer service.


One factor that is apparently overlooked when multiple strategies for improvement are put in place is the direct correlation that exists between them. For example, if the main headings of this document are examined, i.e. poverty, being green and transport, the following can be identified:
• An available, efficient, easy to use and cost effective transport network is required to support employment, our industry, our economy and our society.
• Ongoing green development of our transport network will require industry to provide innovative solutions which will support employment the economy.
• Transport development and innovation hubs will create employment opportunities which will help to reduce levels of poverty.

Something that is worth saying at this point is that there is a place for Artificial Intelligence (Al) and digital technology in our society. However, while investigating possible uses of such technology, there is an underlying requirement to consider the ramifications of any implementation on society, i.e. the benefits of implementing technology need to be balanced against potential negative human impact.

If we consider the desire within businesses, and some echelons of society, to increase the use of driverless vehicles and supermarkets without staffed checkouts, for example, although such moves should help businesses to become more profitable, they will also dramatically increase unemployment levels, the strain on society and, in all probability, poverty. In a society where finding meaningful employment is already an uphill struggle, where will the people displaced by these trends work? Where will they obtain the finances to allow them to purchase goods or services from the very businesses that no longer feel there is a need to employ them?

The aim of this discussion document is to provide supporting information that will empower the West Midlands Combined Authority's (WMCA) to change attitudes, improve services and to create innovative industrial solutions that will improve social standards and help to revitalise the UK's environment. Having said that, it is important to note that implementation of the suggestions detailed in this document can be greatly improved, and become far more efficient, through the introduction of supporting national policies and strategies.

Referring back to my opening remarks, it is worth highlighting how the application of common sense and timely policies and strategies can result in far reaching social benefits. Although the topic being discussed could be interpreted as me "going slightly off at a tangent, it is worth pointing out that it has social, transport and industry relevance.

When it is suggested that many winter driving problems, especially those associated with heavy rainfall, ice and snow, can be overcome by the government passing legislation that requires all• season or winter tyres to be fitted to vehicles during the winter months (in line with existing requirements in Nordic and some European countries), a typical response is "the UK doesn't have enough snow to justify doing that". This is despite the fact that, all too frequently, winter conditions are severe enough to induce panic and to practically bring the UK to its knees (the post New Year period in 2021 has been a prime example). If the reasoning behind making that response is examined, it can be determined that it is ill-considered because it is based on perception and
lack of knowledge rather than the following:
• Most vehicles sold in the UK are supplied with summer tyres.
• A vast majority of vehicle owners continue to drive on summer tyres in the winter months and/or in months where temperatures are known to fall to +7C (44.6F) or below.
• At+ 7C, summer tyre compound begins to harden with the result that (source:
https://www.continental-tyres.co.uk/ accessed 20/01/2021):
• The tyre loses traction even when snow or ice isn't present, e.g. in dry conditions or when it rains,
• The tyre loses its ability to support acceleration,
• Breaking distances dramatically increase,
• The loss of elasticity makes the tyre more susceptible to cracking and chipping
(which shortens its life),
• Damage caused by low temperature use is not usually covered by tyre warranties.
• Frequent gritting/salting; which eats into local authority budgets, is used in an attempt to improve driving conditions without considering that:
• Authorities do not grit unless ice or snow conditions are forecast. Consequently, gritting will not reduce the incidents of seasonal aquaplaning or accidents caused by wet or slippery roads,
• Heavy snow and ice conditions invalidate the use of gritting,
• Gritting will not improve how summer tyres perform in the winter. In fact, slushy conditions frequently make their performance worse.
Passing legislation that requires summer tyres to be replaced with all season/all year or stud-less winter tyres during the winter months would:
• Improve road safety, reduce the number of accidents and save lives;
• Lower insurance premiums;
• Reduce the burden on the police, fire and ambulance/ healthcare
services and motoring
organisations;
• Dramatically decrease the amount of gritting required, its urgency and gritting related local authority costs,
• Increase seasonal employment (more tyre fitters will be required);
• Improve tyre industry, wholesaler and retailer productivity and turnover with a possible resultant increase in employment;
• Allow more tyre retailers to introduce "Tyre Hotel & Swap" services;
• Prevent the road infrastructure from closing down;
• Allow life to continue as normal.


The picture above right was taken in a snow storm in Finland when the temperature was below freezing. When examining this picture, two questions need to be asked. Would traffic, and the transport system in particular, still be moving if the same situation arose in the UK and, would children still be walking home at the end of a perfectly normal school day?

To round this introduction off, I will provide a brief resume.
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An End to West Midlands Poverty:


When poverty in the UK is researched, what are considered to be the leading causes of poverty are easy to identify. They include (source: https://Cpag.org.uk/ accessed 16/01/2021):
• Low paid, insecure jobs.
• Unemployment and constantly having to cycle between periods of work and unemployment.
• High costs and inadequate benefits.


However, what is often missed (and these factors help to feed the issues identified above) are the underlying social, cultural and environmental factors that generate the negativity, dissatisfaction, disillusionment and despondency which contributes to society's "why should I bother" attitude and which, subsequently, can also lead to self-imposed poverty, i.e. people get trapped in a rut of accepting "second best" and substandard conditions.

On the surface, many British people appear to be content with their lives, they are supportive of charities and they are willing to help when asked. Yet, beneath the surface they are constantly paddling against a tide of anger and frustration; an anger that quickly surfaces, swells and over• runs a person when they are brought to task for parking right on the very corner of a busy road junction, with the rear of their van partially blocking the main road and blocking the views of other road users. Does that person apologise for not following the Highway Code? No! Their reaction is
to chase after the person who "insulted" them, endanger other road users by swerving round pulling in front of the "culprit", suddenly stopping dead, getting out of their vehicle and threatening physical violence.


In 2020, the United Nation's "World Happiness Report" 2020 ranked the UK at number 13 out of
156 countries surveyed (Finland was ranked number 1) and ranked London at 36 with Helsinki taking the number 1 slot. This report analyses the results of the Gallop World Poll; which gathers feedback about a country's Business & Economics, Citizen Engagement, Education & Families, Environment & Energy etc performance, and links this information with six other factors: levels of GDP, life expectancy, generosity, social support, freedom and corruption income.

Although the report provides an indicator of the level of happiness in the UK (the Gallop World
Poll surveys approximately 12,900 people or approximately 0.02 of the current population), it may not be truly indicative of the population's feelings as a whole; particularly if those people are totally unaware of alternative ways of life.

So what could improve the UK's ranking in the report and peoples' attitudes?


The primary answer to that question is to implement sustainable changes and systems that will have a positive effect on everyone's daily life and attitude, and that will result in greater efficiencies and substantial cost savings at national and local government level. In short, implement changes that will make everyone's life easier.

National Population Register:


Although it is understood that there would be "big brother is watching you" reservations, the introduction of a generally accessible, fully integrated and dynamic National Population Register would dramatically simplify day-to-day life and result in far reaching efficiencies and cost savings; particularly within local government related operations.

As a minimum, the personal data held in the register would consist:
• Personal Identity Number {PIN).
• Full family name.
• Aliases used.
• Normal place of residence.
• Previous places of residence.
• Place of birth.
• Country of birth.
• Nationality.
• Other nationalities held.
• Gender.
• Native language.
• Marital status.
• Number of children.
• Date of residency approval.
• Date of permanent residency.
• Municipality.


It would be a legal requirement to update the register; online or by visiting a Registry, with any changes, e.g. name, address, marital status, births and deaths and the system would allow individuals to be grouped by residence.

At a national level, the register would provide government departments with accurate and completely up-to-date population statistics and would alleviate the need for the 10 yearly population census (although a 10 yearly snapshot could be taken to satisfy ongoing research requirements).

The PIN; which could have slightly different formats to identify whether a person is a native resident or an immigrant, would be based on an person's date of birth and would be used to identify that person in all contexts, e.g. it would replace NI, NHS and driver's licence numbers and form the initial part of an individual's passport number(s). Additionally, the PIN would be used by, for example, utility companies to identify account holders.

Advantages of such a register include:
• It simplifies address changes - the change would be made in the register and all interested parties; utility companies etc, would be immediately notified.
• Requests to redirect post can be made at the same time as an address change is notified.
• Identity can easily be established when need arises, e.g. in by-law infringement cases.
• Access to healthcare services becomes dynamic (if the healthcare and associated service changes, identified below, are also implemented).
• Alleviates the constant need to prove "right of residency" and "right to work" - particularly when applying for vacancies.
• Reduces the amount of personal and sensitive data that is currently held by different organisations and agencies.

Social Services (Healthcare & DWP) Provision:


Although the lack of a National Population Register would limit the level of efficiency that could otherwise be obtained, with careful planning and changes to existing systems, most of the suggestions identified below could still be implemented, e.g. standardising on the NI Number.

Throughout, entitled residents consist:
• British nationals living permanently or visiting the UK.
• Non-British nationals who satisfy all three of the following criteria (spouses, partners and children forming a family unit ARE NOT automatically entitled unless they are also employed):
• They have been granted "right to reside" status;
• They have been allocated a PIN, and,
• They are employed (any individual who becomes unemployed during the first year of residency loses their entitlement status).
• Any person given special dispensation, e.g. asylum seekers.
• Any non-British national who has gained permanent resident status. Permanent residency would be granted after living in the UK continuously for 1 calendar year. Obviously, because their registrations coincide, spouses, partners and children forming a family unit will also become entitled even if those family members are not employed.

All entitled residents would be issued a PIN related Social Services Card (if a photo-card is used, this also become a form of identity). Entitled residents who have not yet become permanent residents would be issues a temporary Social Services Card. In the latter case identified above, registration as a job seeker in the first year of residency automatically terminates entitlement, i.e. the Social Service Card becomes void.

Benefits, e.g. Universal Credit (UC) or Universal Basic Income (UBI), are only made available to individuals who have permanent residency status. Registration as a job seeker, or notification of temporary lay-off etc, automatically triggers appropriate individual benefit entitlement and payment. The focal point of registration would, therefore, be unemployment, not benefits (as below).

Given the levels of poverty in the UK, from practical experience there is far too much focus on claiming benefits; as opposed to simply registering as being unemployed. Equally, there is far too much reliance on online services. How many people who are near or below the poverty line can actually afford reliable and flexible broadband access computers, printer/scanners and smartphones? Smartphone based internet access is not always reliable and makes system interaction difficult.

Currently, in order to gain access to job seeker services, there is a need to register for Universal
Credit. This process alone could be dispensed with if a National Population Register was introduced. For anyone who does not have broadband access, registering for UC is clouded with frustration. It can involve 2 or 3 wasted visits to JobCentre Plus (an appointment is required before they will actually speak to you), wasted calls to the central Help Line (although they can tell Job Coaches that you want to speak to someone, they cannot arrange an appointment because you have to register for UI first) and approximately 3 weeks of wasted time. Eventually, the JobCentre Plus staff, after you have already told them that you do not have internet access available at
home, may allow you into the offices to use the internet facilities that are available there!


Once UC registration has been completed and approved, job seeker advice can then be obtained. However, most of the Department of Work & Pensions (DWP) help and advice is clouded with the need to constantly apply the "stick"; to ensure that agreed commitments are adhered to without providing any practical job search assistance. This approach also results in unemployed "claimants" being totally ignored once household income rises above the point where UC would be paid. Equally, other government and non-government job/work coach organisations provide
very little practical assistance; only access to information already available elsewhere, e.g. they send out lists of available jobs that are already available on job board sites. Although it is fully appreciated that negative attitudes towards gaining meaningful work exist, the majority do not need to be made to feel guilty for not finding employment, especially when suitable vacancies don't exist or suitable vacancies exist but company imposed requirements prevent them from even applying, e.g. 2 to 3 years experience.

When will governments and authorities realise that job seekers cannot give themselves employment; only employers can do that!

The entire benefits and job seeker system needs to receive a dramatic overhaul to make it easier to access, and to change the focus away from claiming benefits and back to providing practical assistance in finding employment; job/work coaches are rarely, if ever, able to inform claimants of hidden vacancies despite the fact that most of the organisations involved have staff whose responsibility it is to liaise with local businesses in order to track down these vacancies.

Job and work coaching should only be available through government/authority run offices. Private company Work Coaching should be scrapped or more stringent funding rules should be put in place. This is because the current system is too open to the possibility of fraudulent funding claims being submitted, i.e. it is possible to make claims for coaching sessions that were not necessary and/or were not requested by the job seeker(/ know, I have experienced this and my forethought has prevented a claim from being made - and, yes, I do have the evidence!).

Additionally, the Covid-19 pandemic has highlighted the stupidity that exists within the current system. At a time when it is known that far more businesses than normal are failing; with a corresponding increase in unemployment and decrease in available job opportunities, there is
little point in employing more job/work coaches, whose job it is to tell you (in some cases) to apply for 8 non-existent jobs per week and to increase the pressure on you to find employment. All this situation does is to provide temporary employment for a limited number of people and incite further animosity towards the service.

Now that the subject of Covid-19 has been raised, why is it that the pandemic is being used as an excuse for providing a poorer level of customer service than has already existed in this country? Why does it takes a British bank 45 minutes to answer a service call when their counterparts in Finland either answer immediately or automatically engage their call-back systems; which results in a call being made 10 minutes later? Is Finland not experiencing the pandemic? Are those employees not working from home as well?

As above, where Job/Work Coaches are employed, they and their colleagues need to be far more proactive in seeking out hidden vacancies and forwarding these to job seekers (as above). Job seekers need to know about vacancies or possible job opportunities that aren't being advertised. This is especially important when an individual isn't particularly concerned about the type of work they are prepared to do.

Although this suggestion is, to some degree, already in operation, the DWP, or a related local authority establishment, should regularly (on a weekly basis) review the local job market (see also Employment below), to establish:
• The nature of vacancies that exists and their requirements, e.g. what employers are
requesting in terms of experience and qualifications;
• Whether or not the requirements, especially the essential requirements, are realistic
(many are not);
• What local shortages exist and what re-training is required to reduce the skills shortfall, e.g. currently, in the WMCA region, care working accounts for approximately 25% of all vacancies. However, to become a domiciliary care worker, you need the right empathetic attitude and appropriate life skills (too many existing care workers don't have these attributes) and prior training that tells potential care workers what the job actually entails;
• The number of rogue vacancies that are being posted.
• The level of legislative and procedural non-compliance, particularly with regard to PPE
provision. Healthcare:
Everyday healthcare services need to be restructured to make them easier to access; especially
dental services, and easier to use. One major issue that exists in the UK is that dentists are not obliged to provide for NHS customers; dentists opted out when the NHS was created. Even when a dentist claims to provide NHS services, they will suddenly decide not to take on any more patients. For example, when urgent dental work was needed, 4 dental surgeries; who all claimed in external advertising that they take on NHS patients, were contacted yet only the last one decided that they would complete the necessary work at NHS rates. Additionally, when the NHS was contacted prior to contacting the individual dentists, the resultant actions and advice only served to make the situation worse (which was why the individual dentists had to be contacted).

All doctors should be brought under the direct control, and/or employment, of the NHS. Individual practices should only remain if a practitioner wishes to provide private medical services. However, there is also a case for encouraging a dual NHS/ Private health service providing that the Private Service does not encroach on the NHS' facilities, i.e. they establish their own extensive chain of health centres and hospitals etc.

The following suggestions follow Finnish methodology. See https://www.hel.fi/sote/units/en/units-aIphabeticaIly/kaIasatama-centre/

District Health Centres should be established; the number and location of which will be determined by the density of the local population, and these should provide, as a minimum, the following services:
• Healthcare services (doctors, nurses etc).
• Social services.
• Oral healthcare services (dentists, hygienists etc).
• Psychiatric and substance abuse services.
• Physiotherapy and occupational therapy services.
• Services for older people (advisory services, tips for an active everyday life, support at home, nursing and social services).
• Immigrant services (immigration assistance).
• Services for the disabled.
• Contraceptive advice.
• Tobacco Addiction Clinic.
• Laboratory services (sample collection and testing). These services will facilitate testing requests to be serviced immediately by using Queue Ticket systems - following a request being made by medical staff.

Access to healthcare services should be gained by either using an on line request or by telephoning a healthcare helpline (and providing your PIN). The online request system and telephone helpline should be staffed by fully qualified nurses and/or doctors - not receptionists without medical qualifications. This will allow the initial contact to be vetted, with appropriate advice being given, before a request is forwarded to the appropriate service, e.g. before a doctor's appointment is made. This will allow most repeat scripts, for example, to be requested and processed without there being a need for doctor intervention.

The need to pre-register with doctors or dentists etc should be scrapped. Medical staff will be allocated based on availability; although every effort would be made to allocate the same professional. If medical staff are not immediately available in the closest District Health Centre, patients will be allocated services in the next available and nearest centre.

The need to pre-register with pharmaceutical services should be scrapped. It should be possible for patients to visit any pharmacy (within a given area) in order to have, for example, repeat scripts processed. Pharmacies should have access to a centralised Patient Records System. Repeat
script requests can then be accessed by a patient, or their designated representative, by providing
their PIN.


Where long term medication is involved, doctors should be able to allocate up to 2 years worth of medication that can be called off by the patient in periods of (up to) 3 months. This would greatly simplify the process and reduce doctor workload.

Irrespective of their circumstances, patients should be required to pay a contribution towards medication and certain healthcare services. A list of free services, e.g. seeing a doctor and accessing laboratory services, should be published. However, the amount that has to be paid should be capped at (say) £650 per annum. After that, providing that the patient registers the fact that they have reached the payment ceiling, no further payments would be required.

Senior management needs to be made accountably for NHS spending. It is known, for instance, that large amounts of money is wasted on ill-considered and cancelled projects and the purchase of equipment that is never used.

Social Attitudes:


If there is a genuine desire to reduce poverty levels, then there is a high priority need to indentify and combat social attitudes, stigmas and policies that are helping to feed poverty, e.g.:
• Promiscuity and, in particular, engaging in unprotected sex. Safe sex education generally targets the younger generations often without having the desired effect. However, it should also target those who should know better, i.e. the adult population; many of whom appear to have a "couldn't care less" attitude. It has become socially acceptable to have multi-father families where an individual child's parent is forced to pay maintenance
simply because pregnancy is considered to be a suitable precursor to forming a long term relationship.
• Low self-esteem and the belief that it is not worth bothering with education because there are no jobs, that the only jobs available are manual labour oriented and/or because there
is little point in achieving at school because higher education isn't financially achievable or isn't "cool".
• Access to all forms of education, including university based education, should be free of charge. Equally, more bursaries should be made available to those that show a positive attitude towards education and achievement in general. Although currently, and in the foreseeable future, grants are available, these do not cover day-to-day living cost which can be quite substantial.
• British society is highly "social status" oriented and materialistic. It thrives on prestige.
Although nobody should be prevented from owning their own property etc, it should not be seen as being a "right"; nor should owning houses in preference to apartments be seen as being the "norm". Social attitudes linked to this issue include:
• People consider that it is their "given right" to own a property, own a car (especially a "flashy" one) and to regularly go on holidays. Additionally, it is considered that, if they don't own such items, they have under-achieved. Materialistic items often identify "social status". However, the fact that many have to descend into dept in order to afford such items is usually overlooked.
• There is social stigma attached to renting accommodation and living in an apartment. The attitude being that, if you live in an apartment, you have underachieved.
• To have achieved, a house must either be detached or semi-detached, have a bathroom with a bath and, if possible a separate shower, multiple WCs and a garden. It doesn't matter that the garden is postage stamp sized and left to waste or the accommodation is cramped and lacks storage space.
• Society will look after me because I can claim benefits.
• Property prices. Realistically, these are controlled by:
• Social status: Larger and more expensive properties are indicators of status and importance in society.
• Property developers: Irrespective of the amount a development cost; and all too often substandard materials are used to reduce costs, developers will link new house prices to those currently prevalent in an area. Their motivation for maintaining high house prices is profit.
• Estate agent: Agents are the one who generally establish house prices; buyers usually have to take or leave the prices quoted. Higher house prices are established
by:
■ using terms such as "up and coming area" - an area is often only "up and coming" because agents see that potential exists for increasing prices or because a new housing development has been agreed;
■ identifying an area as exclusive or of better "class"; even though that area may be directly linked to another that hasn't been identified as such;
■ proximity to amenities, countryside or views access to amenities is an essential part of life, you don't own views or the countryside that surrounds a property and views and countryside can quickly be obliterated by developers being given permission to develop on green field sites.
• Again, motivation for agents maintaining high house prices is profit. A better, fairer and non-profit oriented way of determining property value needs to be found.
• The quality or condition of the area. Run down and disordered areas will tend to drive up poverty. It drives the "what's the point in trying" and "couldn't care less" mentality. Many of the problems associated with neglect can be rectified by introducing clearly defined operational and development strategies and by ensuring that local authorities do the job that they are paid to do, e.g. keeping streets clean. Policies and strategies that would help to resolve these problems include:
• Clearly defined fully-factored urban redevelopment and rejuvenation strategies
that include replacing aging housing stock. The design of all replacement properties should take into consideration the history and character of the local area both internally and externally. Many people dislike the shapeless and characterless buildings that are becoming prevalent, yet they have no say what is being built.
• Repositioning "out of town" shopping centres, utilising waste land/ brown field sites within the redevelopment process.
• Introducing a vastly improved minimum standard for rental accommodation; fit for purpose, adequate, no damp, safe condition, high standards of insulation, effective double glazing, low cost hot water and heating provision, adequate storage, fitted wardrobes etc.
• Introducing legislative changes that require landlords to install and maintain kitchen white goods and no additional cost.
• Extending "all inclusive" rental availability: rent includes structural, fixtures and fittings and outside area maintenance, council tax (waste disposal etc), sewage, hot and cold water and heating but does not include electricity (see also Housing below).
• Greatly improved waste management, outside area (including streets) maintenance and recycling services (see also Waste Management, Energy and District Heating below).
• Establishing more free electrical goods recycling points in major electrical appliance retailers and ensuring that all household goods and appliance retailers/ resellers are obliged to remove (and hand over to recycling centres) any goods that are
being replaced at only minimal additional cost, e.g. kitchen white goods, furniture, electrical appliances.
With regard to the quality and condition of an area, and its effect on attitudes and feelings, it is worth reviewing two sets of photographs and reflecting on the feelings they conjure up. The first set was taken in Bilston and Willen hall during the last four months of 2020, while the second set contains photographs that were taken in the Helsinki Capital Region in the months of September thru to December.
[See attachments for Images]

While making the comparison, it may be determined that:
• The main difference between the two sets of photographs is the difference in attitude that exists in Finland towards cleanliness and tidiness - they proactively sweep the streets
clean of leaves and remove litter - often overnight.
• Any negative feelings that are generated by the first set of photographs could easily be alleviated by implementing appropriate urban regeneration and waste management policies and strategies.

British & Social Values:


Britain has Social Values and, in order to re-enforce them, it has established a set of British Values which are now being embedded into every school and college lesson and in some training courses (https://www.hsdc.ac.uk/british-values/ accessed 07/02/2021):
• Democracy: A culture built upon freedom and equality, where everyone is aware of their rights and responsibilities.
• The rule of law: The need for rules to make a happy, safe and secure environment to live and work.
• Individual liberty: Protection of your rights and the rights of others around you.
• Mutual respect & tolerance of different faiths and beliefs: Understanding that we all don't share the same beliefs and values. Respecting those values, ideas and beliefs of others whilst not imposing our own onto them.

Unfortunately, although they are being taught in schools, they are not (necessarily) being taught to the children's parents; nor are they sufficiently extensive or satisfactorily enforced.


Modern Technology:


It is now becoming more and more apparent that modern technology; although it is generally helpful (when used correctly), is playing its part in the undermining of social and moral standards. All too frequently, television is being used for child entertainment; as are smartphones and other digital devises, parents are seen interacting more with Facebook than the child that they are pushing along in a pushchair and, despite being made aware of the implications, people still drive and use their phones at the same time without hands-free.

Children are losing the ability to entertain themselves and to coherently speak. When technology is not available, they no longer appear to know what to do. Hobbies, such as model making, book reading, sewing, cooking, flying model planes, sailing boats on the local pond or paddling pool, are becoming a thing of the past. Equally, parents appear to have lost interest in their children. Although they may encourage participation in sport or clubs, they, themselves, are not necessarily participating in that entertainment because they can leave that to someone else.

Such issues have been identified in research carried out recently by Finland's Tampere University
Hospital:
https://yle.fi/uutiset/osasto/news/parents_and_kids_screen_time_use_can_delay_vocabulary_skills_in_young_children_study_finds/12110281?fbclid=lwAR1TUGGiwsjYn7G41nQ44TkHTkEPeflrmw vTcBd_U_Dkfkeorxwy9SWF6YOZk
Many parents appear not to be encouraging participation in non-digital forms of entertainment; they don't sit and read to them or with them, make junk models with them or help them to build "dens" with chairs and blankets or outside in the garden using whatever comes to hand. Parents are more likely to chastise a child for a minor misdemeanour than point them in the right direction; or praise them for something positive that they have done or achieved. Consequently, boundaries are not being set and children are becoming bored, feel unloved or turn to extreme forms of entertainment that reflect attitudes and actions that they witness on television: vandalism (including excessive "street art"), bullying, street gang membership, drugs, other forms of anti-social behaviour etc.

Power of Positivity's website has a very good article which describes seven traits that adults display primarily because they felt unloved as a child. They are:
• Lack of trust.
• Poor emotional intelligence.
• Fear of failure.
• Toxic relationships.
• Insecurity and attachment.
• Depression and anxiety.
• Oversensitivity.


https://www.powerofpositivity.com/behaviors-people-unloved-as-children/
After reading this article, there is a need to ask how often these traits are seen on a daily basis. In previous years, children knew their boundaries, far more parents knew how to raise their
children, digital technology wasn't involved in entertainment and, as a consequence, those
children, in turn, passed on positive attitudes towards discipline, respect and social values to their children.

To overcome these problems, a way needs to be found to teach parents, and those embarking on the path towards parenthood, how to be parents, how to set boundaries and how to support their children as they grow.

Laws & Bylaws:


With reference to the Set 1 {Bilston & Willenhall) photographs above, it should be noted that it is illegal or an offence to fly-tip, to drop litter, to not clear up dog excrement and to park within 10m (32ft) of a road junction, yet it happens regularly on a daily basis. However, what is actually being done about improving such occurrences? In my view, not enough!

We are told by the Keep Britain Tidy campaign that 90% of local councils have a Dog Warden • Wolverhampton possibly has one - but their main focus is "stray dogs, lost dogs, illegal puppy trading, dangerous or nuisance dogs, illegal dog breeding, illegal dog boarding, a pet shop selling dogs". Are they actually being proactive in preventing dog fouling?


Equally, the City of Wolverhampton Council provides a method of reporting fly-tipping and litter, yet they appear to be doing nothing about prevention or ensuring that the mass of detritus that exists in the community is removed. They do not even consider it worthwhile to follow up a suggestion to employ additional street cleaners; nor do they concern themselves about walking around their area of responsibility to determine the extent of the problem. It is also interesting to note that "rag and bone" practitioners often don't bother collecting "street dumped" appliances and other household items left outside properties.

At the end of the day, there is little point in having laws and bylaws unless they are going to be policed and upheld - and lack of visible policing is the main cause of such problems. People now know that, in all probability, they can get away with almost anything. See Overcoming Vandalism.

Education:


The British education system, coupled with social and parental attitudes and lowering moral standards, is failing to ensure that students meet the minimum standards of knowledge and skill required by society. For example, because of ongoing under-achievement, this country has now become obsessed with functional (literacy and numeracy) skills tests. They are, for example, ensconced in job applications and voluntary work induction procedures and they are often a prerequisite to course attendance. Additionally, what makes the matter worse is that, the tests are often completed irrespective of whether the tests have been completed before or they are
actually required, i.e. a candidate already has appropriate literacy and numeracy qualifications and can prove it.

One of the underlying reasons for this upsurge in testing, and this situation in itself needs to be reviewed and corrected, is that the government provides funding for every test taken. This has lead to test and funding culture that is largely based on the needs of the business, or education establishment, rather than the needs of the individual, i.e. funding is considered as a convenient additional source of revenue. But one has to ask, why are these tests and their associated training courses needed in the first place? Isn't it the job of mainstream education to ensure that, as far as is practically possible, students leave school with the correct level of knowledge and
understanding of these topics?


To overcome this problem, education, and schooling in general, needs to focus on ensuring that students (by the age of 16) achieve the required level of personal, social, literacy and numeracy skills, e.g.:
• They are able to look after themselves: they know about personal hygiene, the can cook, sew and carry out basic household maintenance tasks;
• They can tell the time using analogue and digital devices;
• Unless the UK finally decides to standardise on one form of measurement (which it should do), imperial and metric measurement and the correlation between the two systems.
• They are able to use and maintain modern technology, e.g. computers;
• They are confident and have high standards of discipline and respect for themselves, others and their environment;
• They are able to read reasonably complex literature, produce written work to a high standard, do complex arithmetic and, to some degree, mathematics;
• They are able to communicate (read, write and speak) in at least one other language to, at least, B2 level - preferably by the age of 11.
• They have knowledge of their environment and geographic location.
• They have an understanding of the human body and how it works.
• They have an understanding of basic scientific principles.
• They are disciplined and have respect for both themselves and others.


Education should also be far more progressive, i.e. students should only be taught what is necessary at that particular moment, and it should not teach subjects that are of little long term value or that are unlikely to be used - consider how many people have been taught Latin or quadratics over years and who have never had the need to use them. Equally, they should not be taught topics that require educators to learn sufficient knowledge or a subject in order to teach it. Topics, and increased subject complexity, can be introduced as and when required. It also needs to be recognised that, if someone has particular career path already in mind, they have often already attained a high level of subject specific knowledge.

Schools career advisors should not provide advice on careers that they know little or nothing about. Equally, they should not pressurise students into following a particular career path; especially if a student has absolutely no prior knowledge of or interest in that career. All too often, school leavers attend industry specific college courses without have any idea about what the subject is about or what working in that industry actually entails. Again, I have first hand
experience of this happening.


Particularly in the early years (up to the age of 7), children should not be subjected to the pressures and stresses associated with achieving, i.e. learning environments need to be relaxed. Within the 3 to 7 age group, more emphasis should be placed on learning through play, and through taking part in practical activities, than learning through more formalised activities. Stress reduces learning ability and, this factor alone, could be contributing to longer term underachievement.

Homework should be limited to completing tasks that were commenced during education hours and that cannot be completed during school time. Poor lesson planning, and a requirement to impart too much information, should not be the reasons behind allocating homework. Here again, children need to be allowed to be what they are - children! They should have sufficient time to relax, play and participate in out of school activities - and, preferably, in activities that take them away from television and computer screens.

The requirement to wear school uniform should be replaced with the requirement to wear smart, casual clothing. The need to wear school uniform places unnecessary stresses on lower income families where the alternatives are buying school uniform or food. The wearing of uniform doesn't necessarily create a level playing field, or reduce incidents of bullying, because, often, it is just as easy to determine a family's level of income by the standard of school uniform being worn as it is the standard of casual clothes being worn - or from other factors. Not having to wear school uniform also prevents discriminatory and "type of clothing" issues, e.g., girls not being allowed to wear trousers or light boots not being considered (by the school) as a suitable alternative to shoes.

The practical and safeguarding aspects of employment need to be considered. As much as possible, work related student assessment should only occur in the workplace, i.e. when they are actually doing their job rather than being on work placement. In connection with workplace assessment it should be noted that, even when assessment environments are carefully
constructed and professionally staffed in training establishments, some can still not be adequately assessed. For example, although it is possible to construct a care client's home in a college, a full range of assessment is not possible unless professional actors are used in place of clients. Other students will not be able to take on this role because, unless they have "life experience" of domiciliary care clients, they will not be able to act or respond to care worker actions appropriately. Consider, for example, how clients with varying degrees and types of dementia, or those with varying degrees or mental disability, will act and react to different stimuli - even the day of the week can make a difference to how they act.

To overcome current issues, OFQUAL need to structure qualifications to ensure that:
• Irrespective of Level, they are always aligned to industry requirements. Currently, for example, one training provider can develop a Level 3 Certificate in Information Technology course that has limited correlation with the IT industry while another, more forward thinking provider, can develop a course that results in students gaining industry specific accreditation, e.g. Microsoft Certified System Administrator accreditation.
• They always assess the acquisition of knowledge and ensure that the qualifications are worth having. A student being able to research a topic on the internet and to then immediately use the results of that research to answer assessment questions, does not constitute demonstrating acquisition of knowledge; especially when a student also considers that copy and paste plagiarism is acceptable (this often happens with even the simplest of assessment questions and such situations are not helped when training provider staff, frequently and unfortunately, choose to turn a blind eye to such practices and tell their colleagues that "if they value their job, forget about it"!).
• They clearly and unequivocally identify the full spectrum of work associated with an
, industry specific qualification. Currently, students can, for example, complete a Level 3 in Health & Social Care course without knowing that care work frequently requires physical and, often, intimate physical contact with clients, e.g. they are ignorant to the fact that they will be expected to shower clients and to deal with their toiletry requirements. In industries such as care work, work placements cannot adequately provide insight into the scope of work largely because of the overarching and limiting factor of student and industry specific safeguarding.
• They take student and industry specific safeguarding measures fully into account.
Consider, for example, the safeguarding issues associated with a 16 - 18 year old Health & Social Care college student being asked to undress, shower and dress an elderly male
client after first helping him with his toiletry needs. In addition, in such instances, there is also a need to consider the feelings of the client, e.g. would a client feel comfortable having a student the age of a grandchild or great-grandchild administer to their needs?
• They are progressive and allow students to move between different courses, including courses associated with different industries and vocations, without having to abandon all of their previous learning.
• They avoid student related confusion and despondency when it is finally discovered that the 12 month long course they have just completed, and the qualification that they have gained as a result, is not being accepted by industry.
• Vocational courses provide adequate insight into broader aspects of employment, .e.g. employment laws.
• The level attained adequately reflects the amount of work required to attain it and that the correct number of Guided Learning Hours (GLH) is adhered to. Currently, two unit Certificate courses are available. Not only are these easy to obtain (how difficult is it to complete a workbook when you are provided with a textbook containing all of the assessment material?) but unscrupulous training providers are asking students to
complete the associated course, which also includes Equality & Diversity, PREVENT training and assessment and, possibly, CV writing guidance, within 6 working days - only 12 hours of which involve face to face teaching.

In January 2021, the government released its "Skills for Jobs: Lifelong Learning for Opportunity and Growth" White Paper which "sets out how (they) will reform further education so it supports people to get the skills our economy needs throughout their lives, wherever they live in the country." Although, at first glance, the underlying policy appears to be sound, evaluation of the White Paper reveals that it provides an example of where the proposals haven't been fully considered. Of particular concern are:
• The proposals still focus on the principle that people need HE Level 4 & 5 qualifications in order to prove that they can provide industry with the "knowledge and skills that industry requires". Training providers can easily achieve that at Level 3 if they, and those engaged in syllabus design, have a mind to. At the end of the day, unless a course includes practical based, industry specific requirements, such as MCSE and CCNA, the resultant qualifications won't necessarily prove that a person has the aptitude to apply the knowledge and skills covered by the course.
• Adult access to HE courses will require subscription to an extension of the student loan scheme. Free courses, at any level, will still not be available if an adult already holds a Level
3 or above qualification.
• The White Paper does not indicate how students' practical competency can be assessed in industries where safeguarding issues exist, e.g. Health & Social Care (which happens to be one of the target industries identified in the White Paper).
• In order to provide industry specific HE courses, FE colleges will need to employ educators who are already educated to Level 4 or 5, who (preferably) have subject specific qualifications and who definitely have industry specific experience. Where will these educators come from given that, as the White Paper states:

"The majority of people study at foundation and intermediate levels (up to level 2) or at degree level (level 6 and above), with relatively fewer people gaining higher technical skills (levels 4 and 5). Only 4% of young people achieve a higher technical qualification as their highest level by the age of 25, while by comparison 37% of 25- year-olds have only achieved an intermediate (level 2) qualification or below, as their highest level qualification, and 33% achieve a degree level (level 6) qualification or above."

As the White Paper also points out, industry already has a dearth of talent educated to HE level and it is unlikely that those who have the necessary qualifications will wish to leave highly paid employment to be trained to become a lower paid educator; unless, of course, they have an underlying desire to do so. In this respect, consider that a Microsoft Certified Systems Administrator (MCSA) can earn, on average, up to £45,000 per annum (source: cwjobs.co.uk, accessed 22/01/2021) yet an FE College Lecturer with Microsoft Certified Trainer status (the person who helped the MCSA gain their accreditation) may, on average, earn only £29,400 per annum (source: glassdoor.cu.uk, accessed 22/01/2021). It should be noted, however, that HE Lecturers could command, on average, £44,500 per annum. Even so there is still disparity between the salaries.

Additionally, unless this requirement has changed recently, it needs to be recognised that educators cannot teach subjects at a level above their own level of attainment. Consequently, an educator who has a Level 4 qualification cannot teach on a Level 5 or 6 course.

Although the White Paper states that industry will have a far bigger say in the syllabus content; which could vary from training establishment to training establishment and region to region, there is no indication as to how that varying syllabus will be structure into formal qualifications.

Rather than progressing with the proposals as they stand, there is a need to re-evaluate them to ensure that they will actually achieve their aims. Will they result in a more highly educated (at HE level) workforce that can help industry to re-establish itself post Covid-19? Will qualifications gained in one part of the country be accepted elsewhere?


It is considered that the existing Level and GLH structure for vocational qualifications should be replaced by a flexible and Level only system that encompasses the following (minimum) principles:
• Level 1A (or existing Entry Level 3) component:
• All students would be required to complete Level 1A.
• Students who complete Level 1A will be issued with a time limited, non-industry specific completion certificate, e.g. 2 year validity to allow for legislative changes.
• Students who have not completed Level 1B within a year of completing Level 1A will be required to complete Level 1A again (or a relevant Level 1A refresher course).
• Level 1A units should cover:
• Employment laws, e.g. the working time directive etc.
Health & Safety at Work, e.g. risk assessments, the provision of PPE etc. First Aid.
General digital, literacy and numeracy skills (if not already attained).
• Assessment will utilise List, Describe, Explain, Evaluate and Demonstrate criteria
with Demonstrate, in particular, being an important aspect of First Aid and Health & Safety assessment, e.g. can they administer First Aid, can they complete a Health & Safety Risk Assessment?
• Level 1B (or existing Level 1) component:
• Level 1B cannot be commenced until Level 1A has been completed.
• Students who complete Level 1B will be issued with an industry specific completion certificate and be allowed to progress to Level 2.
• If, after completing Level 1B, a student decides to withdraw from the course because, for example, they have decided that "that particular job is not for them", they can elect to enrol on another industry related course; entering at Level 1B providing that their Level 1A certification has not expired.
• Units would clearly and unequivocally describe what the selected job actually entails, e.g. showering people, serving food, clearing and cleaning table, greeting customers etc. Ongoing interaction with industry will ensure that the latest practices are taught.
• Assessment will utilise List, Describe, Explain and Evaluate criteria. Demonstrate will not be required as this Level only requires knowledge based assessment.
• Level 2 component:
• Students who complete Level 2 will be issued with an industry specific completion certificate.
• Students who complete Level 2 would be accepted into the workplace providing that they enrol, or have enrolled, onto a Level 3 course.
• Units would cover industry specific:
• Knowledge, e.g. how something works.
• Skills that do not require the student to be employed in the industry or that can be assessed using techniques that overcome work related legal and safeguarding issues, e.g. using a hoist, serving alcohol in pubs or restaurants b using a mock-up bar (age restrictions).
• Digital, literacy and numeracy skills.
• Assessment will utilise List, Describe, Explain, Evaluate and Demonstrate criteria.
Demonstrate is required as the application of knowledge and skills will be assessed.
• Level 3 component:
• Students who complete Level 3 will be issued with an industry specific completion certificate.
• Units would cover:
• Industry specific knowledge that needs to be assessed in the workplace, e.g. that the student is not administering medicine that does not appear on a client's Medicine Administration Record (MAR) chart.
• Industry specific skills that need to be assessed in the workplace, e.g. life and empathy skills, being able to administer to a client's physical needs.

In addition to the above:
• Level 1A and 1B completion would be prerequisite to starting any apprenticeship.
• Level 1A and 1B can be completed by anyone who already has non-apprenticeship related full or part time employment.
• Level 2 would be:
• Completed during an apprenticeship.
• Prerequisite to commencing non-apprenticeship related full or part time employment in certain industries, e.g. the care industry.
• Completed by any who already has non-apprenticeship related full or part time employment.
• Level 3 would be:
• Completed during an apprenticeship and prerequisite to completing an apprenticeship.
• Completed by anyone who already has non-apprenticeship related full or part time employment.

"Level" accreditation should not be awarded for training that, traditionally, has an expiry date, e.g. first aid, food hygiene. Traditional course completion certificates should be issued.

Disabilities:


People should generally be discouraged from finding excuses for underachievement. Equally, assessing organisations need to be realistic but firm; especially with regard to self-imposed disabilities such as obesity. All too often disabilities; perceived or otherwise, are used to introduce barriers to learning and achievement. Underachievement can, to some degree, be expected if someone has genuine and major learning difficulties or disabilities. However, improved personal and social attitudes, supported by the provision of appropriate facilities and proactive training, do help to overcome these barriers.
[REDACTED- GDPR]
Even severe disabilities, which are also used as excuses for underachievement and not being able find employment, can be overcome if the correct resources are made available. The following video highlights that, when the mind is willing, achievement holds no bounds.


https://www.youtube.com/watch ?v=XB4cjbYywqg


Courses and practical guidance, aimed at overcoming barriers to work, should be made more readily available, e.g.
• Providing assistance in identifying alternative vocations, and providing training in those vocations, when someone is diagnosed with Age Related Macular Degeneration {AMD).
• Providing guidance and assistance to achieve weight loss and increased health.


Employment:


Especially now while the UK is still in the throes of the Covid-19 pandemic, it is an employer's market. Over time, society's negative attitudinal changes, and the lack of enforcement of employment legislation, has resulted in employers (knowingly or without due diligence) preying on the fact that many job seekers do not know employment laws and that they will accept any employment conditions in order to gain employment. In addition, employers frequently take advantage of employees' good will. A simple survey of current job vacancies can identify these facts. However, in order to re-enforce this statement, an everyday example will be used.

Recently, the press and the population in general have been extremely open about their praise for Health Workers. For example, they have stood out on Thursday evenings and applauded their efforts. Yet how many of those people who have applauded, and this includes the government, bother to find out about, or are prepared to do anything about, the working conditions that some of these workers have to endure or have imposed upon them?

Are people aware, for instance, that Domiciliary/ Community Care Workers' frequently face the following conditions of employment?:
• They may be paid an hourly rate that is only just above the National Minimum Wage
(NMW) / National Living Wage (NLW).
• In addition to the hourly rate, they may be paid an additional allowance for each client they attend.
• In order to gain employment, they will have been OBLIGED to purchase a car. Most care agencies do not provide carers with vehicles and it is often next to impossible to do domiciliary work without a vehicle (the only option that is sometimes available is permanent "double-handed calls"). Often job application processes terminate if an applicant indicates that they do not have access to a car. This raises the following issues:
• The care worker immediately becomes responsible for ensuring that they can continue working.
• If the car breaks down, or it requires servicing or an MOT, the care worker cannot work unless a courtesy car is provided or a car is rented.
• If a car is rented, the care worker cannot claim the additional expense against tax.
• When there is a need to replace the car, unless sufficient savings are available, finance will need to be found.
• Insurance premiums are higher because business use is required.
• None of the costs associated with the purchase of a vehicle can be off-set against tax because the care worker is not self-employed.
• Domiciliary Care Workers do not receive any fixed amount of wage. Their entire wage is calculated from the number of client calls made or training hours attended. Consequently, if a client gives 24 or 48 hours "call cancelled" notification, or a clients care package is cancelled in entirety, i.e. they no longer require care, both the number of hours worked and the corresponding wage received decrease.
• Rarely are breaks programmed into the call schedule. Consequently, care workers take their breaks if, or as and when, the opportunity arises. Unless any gaps in a schedule allow it (in which case they will drive home for a break), breaks are spent sitting in their car outside a client's house.
• Mileage may not be paid. All work related mileage then has to be recorded so that a claim against tax can be submitted at the end of the year- and that claim could be quite substantial. Consequently, it can be determined that the employee is subsidising the employer. For example, it is not unreasonable to find that an urban car worker has driven
245 miles in a week; a rural care worker would drive far more than this. If the care worker
works 48 weeks per year, then they will have driven 11,760 business miles in the year. The current non-self employed mileage rate is 45p per mile for the first 10,000 miles and 25p per mile thereafter. This means that the care worker will be subsidising the employer to the tune of £4,940 (and that makes no consideration for the purchase of a vehicle).
• Travelling time is often not paid - and this includes (possibly) the fortnightly visit to the care agency that is required in order to replenish PPE and to collect rotas. The Working Time Directive (WTD) states that travel time is counted as working time when (amongst other things):
• If you travel as part of your job.
• If you don't have a fixed place of work - in which case travel between home and work at the start and end of the working day is also counted as work time. Domiciliary Care Workers do not have a fixed place of work, they work from home.
• Unless a request is made to cover other calls, which can happen quite regularly, over a two week call rota cycle, they may work 4 half days and 8 full days and take the remaining 2
full days off. However, and the WTD has to be considered at this point:
• A half day may start at 07:30 and end at about 13:30. Requests to extend the half day to a full day will occur.
• A full day's hours may be 07:30 to 13:30 and 15:30 to about 21:30. Requests to attend additional or alternative calls may result in the day starting at 06:30 and/ or ending at 22:30.
• Requests to cover calls during rest periods will be received.
• When working full days, in effect (as a minimum) 12 hours out of 14 hours will be worked. However, because actual travelling time is not included in the calculations, the care worker will only be paid for approximately 10 or perhaps 11 of those 12 hours.
• Over a two week period, they will "officially" work 52 hours per week but, in actuality, they will be working 60 hours per week. It is probably that no "Opt-Out Agreement" will have been signed despite that fact that the worker is exceeding the 48 hours maximum, averaged over 17 weeks, specified in the WTD.
• The WTD states that "workers have the right to 11 hours rest between working days". In this example, only 10 hours are available between working days and, on occasion, only 8 or 9 are available.
• Once per fortnight there is a need to visit the agency's office to collect PPE and/ or rotas. No travel time, at least, is paid for this journey and, in all probability working time won't be paid either.
• Because they are working in a client's home, some aspects of Health & Safety legislation no longer apply, e.g. the legal requirement for employers to ensure that the working environment is clean and tidy and free from risks to health. It isn't difficult to imagine the working conditions that exist in a household where the occupants require care, i.e. they are incapable of looking after themselves properly, yet their household also comprises a large menagerie of pets that are not house-trained!
• Being refused admission to, and being locked out of, a client's premises simply because another member of the client's family isn't prepared to stop smoking while the care worker is there.

If such workers are truly appreciated, then there is a need to cease these imposing and unhealthy work conditions and practices.
The government's NMW / NLW calculations are a farce primarily because the working environment used to justify the values presented, i.e. 37.5 hours per week, cannot, for many, be realised. The NMW and NLW and are frequently used by businesses to cap their employee's wages and, when this capping is coupled with a limited number of hours, then the result is less than satisfactory- unless, that is, a person manages to find more than one job.

A survey of job boards will highlight the fact that, all too often, businesses offer NMW (or less) in return for less than satisfactory working hours or conditions. Frequently, in addition to only offering the minimum wage, employers ignore important employment legislation. For example, care workers are not given 11 hours between each shift, they are not paid for travel time; only call time, and, elsewhere, manual labourers are often required to provide their own PPE.

This attitude has resulted in a "slave labour" environment where employees have only two choices: accept the offer or look somewhere else. Additionally, employers are known to abuse apprenticeship schemes by taking on apprentices without having any intent to:
• Place them in a supervised training environment,
• Provide them with any formal qualifications, or provide them that have little relevance to the industry.
• Specify the apprenticeship period,
• Take them on permanently at the end of the apprentice period, i.e. they say goodbye to one apprentice and then take on another.
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It is interesting to note that, in the government's "Skills for Jobs" White Paper (January 2021), it is stated that "While apprenticeships will continue to require a minimum duration of 12 months
with at least 20% of an apprentice's time spent in off-the-job training, we will work with employers, training providers, and the Institute to enable apprentices with significant prior learning to reduce the duration of their apprenticeship and reach occupational competence more quickly."

This statement actually raises one major concern that is linked to the "abuse" comments above. If a person has "significant prior learning"; which could also indicate that they have prior accreditation, can they actually be classes as being an apprentice? If this is the case, what is the justification in employing them as an apprentice and, probably, only offering them apprentice
level NMW? Such situations, which often benefit employers' profits, result in apprentices being used as cheap labour, i.e. the apprentice takes on the responsibility and work of a skilled employee without receiving the correct levels of remuneration, training and support.

Another issue that job seekers face is that, even though they may have the necessary aptitude and underlying skills and knowledge, they do not meet an employer's essential experience and qualification criteria. This creates a "chicken and egg" scenario. Unless the job seeker is able to fund, or find funding for, courses or is able to gain industry specific employment (where qualifications can only be completed if an individual is employed in that industry), they will not be able to gain the necessary qualifications or experience. It should be noted that the experience and qualification scenarios in question extend beyond that which can be obtained by attending any of the general job seeker training that is currently available (generally available courses include
health & safety and forklift truck driving).


The following is a list of personal requirements that regularly appear in job adverts and which are, in essence, barriers to employment (these ignore requirements that can be overcome by training, e.g. fork lift truck license, IT skills:
• CSCS Cards. Usually the type of card required isn't specified. Temporary cards are issued if an applicant doesn't have formal construction area specific qualifications or membership of a professional body.
• Use of your own vehicle. Two issues: obtaining a vehicle on the premise that you will be offered employment and (as previously stated) what happens when that vehicle breaks down?
• Excessive or unnecessary periods of previous experience. These can range from 1 year to 5 years.
• Must be able to show continuous employment. Again, the period required can extend to 5 years.
• As previously mentioned, have your own PPE, especially safety boots. It is a legal requirement for employers to either provide the appropriate PPE; which is determined by completing a risk assessment, or to finance the purchase of suitable PPE.
• As mentioned above, qualifications that can only be obtained by working in a particular industry. One example that appears occasionally is the requirement for care home cleaners to have Level 3 Health & Social Care qualifications.
• Must have your own tools.
• Must be able to lift 25kg or 30kg loads. The maximum recommended weight for a man is
25kg. The need to lift weights should be minimise by the provision of equipment.


The current Universal Credit scheme only serves to exacerbate such situations. Although a potential applicant can request the training from the Department for Work and Pensions, it is unlikely that course funding will be made available:
• In a timely manner, e.g. the authorities may take 6 months to arrive at a funding decision.
• Unless multiple funding requests for the same training are received, i.e. they will not fund individual request even though many job vacancies are individualistic in nature.
• Until tenders for course provision have been processes and a training provider (who may not actually provide the exact course required or who may not be located anywhere need the applicant) has been selected.

Consider, for example, someone who has a good working knowledge of data protection legislation that has been gained in a business environment over a 2 year period. However, because of cost constraints at the time, they have not been able to attend any formal training courses or been
able to gain recognised data protection accreditation. They see a number of vacancies that specify four years experience in a data protection related role, International Association of Privacy Professionals (IAPP) membership and CIPP-E (or EU), CIPT or CIPM accreditation. Although the period of experience may be negotiable, and even though they have the required aptitude, skills and knowledge, it is highly unlikely they will be selected for interview because they lack the required accreditation (which supposedly proves that the applicant has the required aptitude and that they are able to apply their skills and knowledge).

In order to overcome these issues, the following should be considered:
• Implement revised Universal Credit or Universal Basic Income (see Benefits) and an NMW / NLW structure that is more realistic and that allows far more Adult Apprenticeships and
"on the job" training schemes to be established.
• Enforcement of the correct apprenticeship working conditions. This can be partially achieved by colleges and agencies not offering apprentices or apprenticeship courses to businesses that abuse, or who are known to abuse, the system.
• Increase employment opportunities by encouraging Adult Apprenticeships and "on the job" training schemes. These situation should not be subject to the Apprentice NMW, i.e. individuals should, as a minimum, receive the NMW appropriate to their age. Such schemes would benefit both the +16 age group and the aging population.
• Enforcement of legally governed working conditions by the appropriate authorities, e.g. the Health & Safety Executive (HSE) and the Care Quality Commission. Currently, the HSE will not pursue a complaint against a business for non-compliance with legislation unless the complainant is actually employed by that business, e.g. they will not generally investigate PPE provision or Working Time Directive non-compliance even though non• compliance is evident in job board adverts.
• Ensure that employment legislation takes into account the diversity of working conditions.
• Ban all zero hour contracts - either a business wants someone or they don't. As a minimum, businesses should offer a reasonable retainer.
• Encourage employers to be more proactive and sensible about their job offers, e.g. cleaner vacancies. Why offer multiple, +6 hours per week contracts (e.g. 2 hours per day, mornings or afternoons, on Mondays, Wednesdays and Fridays, 3 hours per day, morning or afternoons, on Mondays, Tuesdays and Thursdays, etc) when those contracts can easily be combined into a single employment opportunity (that can be achieved by using public transport?). Although employers argue that arrangements such as this provide them with greater flexibility and the ability to cover sickness etc, the same can be achieved through better staff scheduling, overtime and management cover.
• Enforce realistic and reasonable Pay Ratios; particularly in local government. Senior management should not benefit at the expense of the employee. This is particularly the case in local government.


Housing:


Homelessness is an issue which, at a basic level, can be reduced or overcome by the application of a widely discussed, but often ignored, solution. It is known that a large number of large properties, such as hotels, public house and disused military establishments lie empty and are left to become vandalised and derelict. To augment the limited number of "Housing First" that are being built, these properties should be requisitioned and turned into permanent, or staged, accommodation for the homeless; not just hostels. Employment can be increased by taking on hospitality, management and support staff.

Additionally, especially where military establishments are concerned, the homeless themselves can be encouraged to work in certain functions especially if they have prior training and experience, e.g. consider the number of ex-service personnel who are homeless but have hospitality or engineering backgrounds.

When providing these homes, there is a definite need to ensure that in-house services are always available so that those who have mental health and/ or criminal backgrounds can be catered for. Equally, these homes should be treated as such. Residents shouldn't be forced into taking part in unwelcome activities which only serve to make them want to return to homeless living.


https://theconversation.com/why-some-homeless-people-prefer-sleeping-rough-to-hostels-or-hotels-139414

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At a general level, there is a need to review the quality and suitability of existing housing stock, some of which will not be able to be improved by installing insulation, and to provide high quality, low cost housing. Many people have resorted to accepting substandard housing conditions because there is little else available in their price range and landlords, even those associate with
local authorities, are not obliged to maintain a minimum standard of accommodation. Examples of issues that are accepted include: rising damp in part caused by underlying structural issues or
leaks, single glazing or poor quality double glazing, draughts and cold caused by poorly converted and insulated outbuildings and open fireplaces, poor quality central heating and hot water provision, rickety and sloping staircases and degraded internal fixtures and fittings.

To overcome these issues, it should be a legal requirement for landlords, at their own expense, to maintain properties at least to an enhanced minimum standard; keeping in mind that any minimum requirement soon becomes the normal standard (take NMW as an example). With regard to this, although it is currently illegal for landlords to continue renting properties with an Energy Performance Certificate (EPC) rating of F or G after 1April, 2020 (In 2019, the Residential Landlords Association (RLA) estimated that around 290,000 rental properties did not meet the E
rating standard), because an EPC only provides a perceive level of energy efficiency rather than an actual level, many more properties that actually need improvements will be missed. Additionally,
if there is a strong desire to reduce, or eliminate, poverty, the minimum EPC rating should be much higher (see also The Cost of Energy below). If doing so restricts the number of private landlords, then that may be an additional bonus because many existing landlords see rental as an easy form of income; with the consequence that they need to be constantly "reminded" to carry out structural repairs and, equally, many not aware of, or chose to ignore, their legal responsibilities and, besides, who is policing them?

The following is an example of what does actually occur. A mid-terrace, Victorian rental property is issued an EPC rating of D. This is because it has double glazing fitted throughout; 6 to 8 inches of loft insulation; a reasonably new combi-boiler and energy efficient light-bulbs are used throughout. However, although this situation is commented upon, there is no roof or wall insulation in the kitchen or bathroom and the property does not have cavity walls (so no insulation); the temperature of the external end of the bathroom rarely goes above 12C when the external temperature is +6C or below, the combi-boiler is inefficient (in terms of gas and water use) partially because the heating and hot water pipes are not insulated and are run in wall and floor cavities that are subject to severe draughts and the double glazing is ineffectual (the seals, particularly in the corners, are incomplete and the quality of the glazed units is doubtful).

[See attachment for images]

The pictures to the right and below illustrate the effect of poor wall insulation and ineffective double glazing. They were taken at 07:40 following a day of snow. At the time when the photographs were taken, the external temperature was approximately minus 1C. However, the overnight temperature had fallen to below minus 4C. The snow-melt on the window sill in the first picture extends 10cm (4 inches) from the window frame and much of the snow-melt in the second picture occurred while it was still snowing. At its maximum it extends 50cm {20 inches) from the wall. It should also be noted that the clear patch of ground at the bottom of the second picture is directly outside a pair of double glazed patio doors; which make up most of the house wall at that point.


It is strongly suggested that the EPC rating system is reviewed so that it is more likely to reflect the actual energy efficiency of the property and that previous home improvement grant schemes are revisited. Rather than attempting to improve the insulation levels of many of the existing, aging properties (insulating the kitchen and bathroom in the example property would require major structural changes and would result in an almost unusable galley kitchen), it focus on providing grants for those properties that can be easily improved and initiating a replacement policy for those that cannot.

Additionally, grant schemes need to be extended ensure the energy efficiency of all properties irrespective of ownership. Currently, there the focus is on improving levels of insulation and installing
double glazing or secondary glazing (and, latterly, with replacing gas and oil boilers with electric systems). This is of little use in situations where insulation levels are sufficient but other issues, which can be
easily resolved, are resulting in energy inefficiency and poor living conditions. Equally, such schemes are not normally available to private landlords. Consequently, many of the properties that are in dire need of improvement are neglected.

More low-rise apartment buildings; a basement level and 4 accommodation levels, owned and managed by not-for-profit management companies (for leasehold apartment buildings and for those designated as being for "rental" only) should be constructed. Such an approach makes far better use of available land, speeds up the process of providing accommodation, is likely to be more cost effective and ensures that the integrity of the accommodation is maintained.

For example, in addition to being able to accommodate a minimum of 8 families in 2 or 3 bedroom apartments, or up to 16 individuals or couples in 1 bedroom apartments, in an area occupied by 5 Victorian terrace houses, the residual garden space, when combined with space derived from removing roads, can be turned into green space community areas comprising waste management facilities, trees, grass, children's play areas and BBQ/communal meeting facilities.

The plan below illustrates what can be achieved.
[See attachment for Images]
The area covered by this plan is approximately the area covered by 2 rows of 15 Victorian houses, standing back to back (and including their gardens), a road and another row of 15 houses without the gardens. In its current form, this arrangement provides 128 homes (in place of 75 homes), with either 2 double bedrooms or 1 double bedroom and 2 single bedrooms, that are all disabled
person ready and that provide far greater comfort for the families concerned.

All apartments would benefit from (preferably) district heating; individual apartment storage and communal sports equipment storage (bicycles etc) in the basement; laundry facilities in the basement; pre-wiring for satellite and or cable television; a minimum of 10Mb internet access; remote electricity metering; communal waste disposal points; underground car parking and communal parkland.

The numbered items on the plan are:
1. Access to the underground car park and, where required, shop loading bays. Access to the car park would be via access points in the basement of each building.
2. Wooden gazebos with BBQ facilities.
3. Childrens' play areas.
4. Communal waste disposal points.

In order to match the character of the local environment, front and rear elevations would be representative of any time period. This image from Property
Investments UK provides an example of the external appearance that could be used for shops, offices and low rise apartment buildings. People are attracted by history, charm and elegance; the Black Country Living Museum is a prime example. There is no reason why Bilston, or any other West Midlands town, couldn't ultimately benefit from increased tourism - especially once the canals in the region have been cleared of rubbish! All it needs is a bit of imagination and forethought.

In support of the Fully-factored Urban Regeneration principle (see below), the modular design (see below) can be adapted to provide:
• One bedroom apartments alongside flexible 3 to 5 bedroom apartments (3 double bedrooms, 2 double bedrooms and 2 single bedrooms, 1 double bedroom and 4 single bedrooms).
• Any combination of shops, offices and apartments.
[See attachment for Images]

As previously mentioned, all rentals should become "all inclusive", i.e. rent should include (as a minimum):
• The accommodation - which includes the provision of fitted wardrobes, storage facilities and a reasonable sized fridge-freezer.
• Maintenance of the building's fabric and accommodation fixtures and fittings, e.g. taps and blockage clearance.
• Maintenance of all outside areas.
• Redecorating the accommodation prior to a new tenant taking over the property: costs for fair wear and tear decor deterioration remedial action would be accepted, all other costs would be taken from the tenant's deposit.
• Provision of hot water and heating; preferably by using district heating.
• Provision of cold water - a small, per person additional charge would be acceptable where water meters are installed, e.g. £10 to £15 pound per person, per month.
• Sewage disposal.
• Household waste disposal.
• Optionally, electricity - although electricity contracts would normally be arranged by the tenant.
• Broadband access - "free" broadband would be lower speed, e.g. 10Mb. Tenants would pay extra for higher speed broadband. There should be no need to have a telephone "landline" number allocated.

All new housing developments should be subject to the following requirements:
• They must be part of a clearly defined Urban or Local Development strategy that includes:
• Provision of District Heating: sources of District Heating must be made available in the first instance.
• Restructuring existing buildings and roads to bring out-of-town shopping centres back into town centres, to provide more centralised sports and leisure facilities, to maximise the use of public transport services, to remove derelict and substandard buildings and to maximise the use of brown field sites.
• Increasing the amount of land available for leisure purposes, pasture and woodland.
• Includes nature as a key component to all developments, e.g. surround developments with nature rather than generating pockets of nature.
• Provision of additional services, e.g. sewage treatment, healthcare centres, additional schools and leisure facilities (indoor and outdoor).
• Safeguards against flooding etc., e.g. adequate drainage.
• Increase provision of long distance foot and cycle paths.
• They can only be developed on existing brown field or previously developed land or scrub land.
• They must meet, or preferably exceed, an improved minimum standard for energy efficiency. For example, the following must be included in the design:
• High levels of wall, roof and under-floor insulation.
• Triple glazing.
• Photovoltaic roofing, i.e. tiles and not necessarily solar panels.
• Air Source Heat Pumps installed at roof height (to maximise the capture of escaping heat) possibly disguised as chimneys (particularly if a historic look to a property is to be maintained).
• The use of District Heating throughout (gas fired systems must be phased out): Hot water feeds must be run to, or within 2m of, the point of use.
• All final taps must use microbore pipe.
a An "always on" radiator (this can be in the form of a towel ladder) must be provided in all bathrooms (reduces condensation build-up and damp plus the bathroom can then double up as a drying room).
• All heating must be thermostatically controlled and always available irrespective of season (considers the elderly etc.).
Must be able to fully support the use of all outlets at the same time without loss of pressure.
The following pages show what can be achieved in terms of quality of accommodation versus rental costs. A comparison is made between renting a property in Finland and an equivalently priced property in England (including additional storage overheads) and highlights the facilities that are, or are not, included in the rent. Although the final monthly costs appear to be similar, it needs to be considered that:
• The Finnish apartment is only 5.5 miles (approx) from the centre of Finland's capital city. As is the case in the UK, rental costs and property prices are significantly lower in outlying towns and cities. However, it should be noted that it is possible to rent and equivalent apartment in Tampere (the equivalent of say Birmingham) for between 100€ and 200€
(£88 to £177 approx) less that the example shown. Additionally, equivalent local municipality accommodation is available in Helsinki for approximately €690 (£612) per month.
• It would cost at least £1,395 per month to rent an equivalent mid-terrace property in (say) Tooting-which is approximately 6 miles from the centre of London.
• The standard of rental accommodation and the facilities provided in Finland are much higher than those found in England.
[See attachment for Image]
Finland: 62.5 sq m/672.75 sq ft, 2"floor apartment in a 4 story apartment, located 5.5 miles
(approx) from Helsinki City centre, comprising:
• Unglazed balcony.
• Efficient triple glazing (inward opening to ease cleaning).
• District Heating (including hot water).
• Cold/ drinking water provision.
• Fixture and fitting maintenance.
• Sewage disposal.
• Household waste disposal comprising separate bins for:
• Cardboard/ cartons,
• Paper,
• General/ mix waste,
• Glass,
• Metal,
• Bio,
• Plastic
• Periodic skips for unwanted furniture and household items,
• Clothing recycling point within 500 yards.
• Professionally redecorated and fair wear and tear damage rectified prior to occupancy.
• Internal temperature monitoring (target: 21C).
• Fully equipped children's play area (swings, slide, sandpit, toys, picnic table and benches).
• Communal washing lines.
• External and ground maintenance (grass cutting, rubbish clearance and leaf, snow and grit clearance).
• Launderette comprising 2 x industrial washing machines, 1 x industrial tumble dryer, hand washing facilities, 1 x warm drying room, 1 x cool drying room.

• External bicycle racks.
• Carpet beating racks.
• 2 sq m / 21.5 sq ft (approx), floor to ceiling basement storage compartment.
• Communal bicycle, sports equipment and pushchair/pram storage room.
• 10Mb internet access.
• Small walk-in wet room comprising shower, toilet, sink, handheld bidet shower, bathroom cabinet, shaving
point, always on radiator (linked to the hot water feed) and washing machine connections.
• 1 x large double bedroom complete with fitted wardrobes.
• 1 x medium double bedroom complete with fitted wardrobes.
• 2.5 sq m / 27 sq ft (approx), floor to ceiling shelved cupboard space.
• 6.25 sq m / 67.25 sq ft (approx), floor to ceiling walk-in closet/store.
• Galley kitchen comprising ample cupboard space, electric hob and over, extractor fan, large fridge-freezer, industrial double sink and drainer, dishwasher space (dishwasher optional but supplied free of charge).
• Large "L" shaped living room/ dining room.
• Access to communal sauna (10€/ £8.90 per month extra).


Monthly costs:
• Rent: 1025€ / £940 (approx).
• Electricity: 30€ / £28 (approx)
Total monthly cost: 1,055€/ £968 (approx). Other factors:
• Household contents insurance.

[See attachment for Images]
England: 82 sq m / 882.5 sq ft (approx), Victorian mid-terrace house comprising:
• Draughty double glazing (incomplete and worn seals).
• Gas fired combi-boiler (heating and hot water).
• Cold/ drinking water provision.
• Sewage disposal.
• Household waste disposal comprising separate bins for
• mix cardboard, cartons, paper, glass, metal and plastic,
• general/ mix waste,
• clothing recycling point within 500 yards.
• Fixtures and fittings maintained.
• Private rear garden with small garden shed, shared rear access, small front garden
• Draughty bathroom comprising bath with over bath shower, toilet and sink (ladder towel rail recently fitted and linked to the heating system).
• 1 x large double bedroom complete with fitted wardrobes.
• 1 x large double bedroom.
• 1.2 sq m / 13 sq ft (approx) under-stairs cupboard.
• Galley kitchen comprising cupboard space (additional wall cupboard fitted by tenant), extractor fan, standard sink and drainer, boiler cupboard and tumble dryer space.
• Small living room with electricity and gas meters and open, unusable fireplace.
• Small dining room with open, unusable fireplace and doors to the garden.


Monthly costs:
• Rent: £575 (increasing to £600 in August 2021).
• Electricity: £38 (approx).
• Gas: £30 to £122 depending on the season.
• Broadband (30Mb): £25 (eventually rising to £33, plus £10 activation fee).
• Council tax: Band A= £106 (excludes UC discount).
• Water rates: £20.
• Household storage & insurance: £43.76 per (long term rental, insufficient storage space in the house).
Total monthly cost: £837.46 to £929.46 (approx). Other factors:
• Household contents insurance.
• Tenants purchase their own fridge-freezer.
• Tenants purchase their own hob and oven (tenants have taken responsibility for the existing integral gas hob and electric oven).
• Annual cost of gas hob safety check.
• Decor is "as left" by the previous tenant.
• Damp patches internally on external and partition walls.


There is an image on Page 22 of "Images of England: Bilston, Tettenhall and Wednesfield (Mills and Williams, Tempus, 1998) which is captioned:


"Coseley Road and Prosser Street. These buildings were subject to No. 3 Clearance Order
1934 and were subsequently demolished. In the 1930s Bilston carried out inspections on a large number of properties to determine whether they were fit for habitation, being mostly free from damp, satisfactorily lighted and ventilated, in good repair with a satisfactory water supply, washing accommodation and sanitary arrangements. Any buildings which were deemed to be unfit and which could not reasonably be repaired became the subject
of clearance orders and were demolished."


Although those houses in Coseley Road and Prosser Street were far worse, given the conditions that some people are living in today; no hot water and/or heating, damp walls, insanitary bathrooms, draughty interiors, decaying woodwork, leaking roofs, broken single glazing and crumbling brickwork etc., has the UK progressed much in 84 years?

Public Transport:


Public transport has a major part to play in helping to reduce poverty levels. All too often job adverts state "own transport required because of location" or indicate that shifts start or finish in the early hours of the morning (when public transport isn't generally available). Consequently, these vacancies become inaccessible to anyone who doesn't have their own vehicle or who cannot organise some form of alternative transport.

To overcome these issues, there is a need for an environmentally friendly, flexible, easy to use public transport system that is also available to those who work "unsociable hours", e.g. night• shift, early/late shift workers who finish at 02:00. See An Easy To Use Transport Network.


Benefits:


It is widely recognised that the current Universal Credit based benefits system is far from adequate - particularly when benefit caps are imposed. However, will the introduction of a Universal Basic Income (UBI), as advocated by, amongst others, the Green Party, actually achieve one of its aims, i.e. to reduce or alleviate poverty? The quick answer to that question is, in fact, no!

The following tables provide comparisons based on assessments obtained from "entitledto" Universal Credit calculator where:
• Actual monthly rental costs = £929.26
• Postcode = Wolverhampton
• There are 2 occupants in a 2 bedroom home (no children)
• Gross earnings for any occupant is £1,398.10 (1254.05 after tax and NI)
• No pensions or other forms of income.
• Council tax band= A (liability= £1,270.63 yearly).

Standard UC: Standard Universal Credit Allowance= 2 x £297.02
LHA: Local Housing Allowance
CT Support: Council Tax Support or Salary Deducted
Universal Credit Standard LHA: CT Total Housing Residual
Employment Status: UC: Support/ Benefits: Costs: Income
Salary Including
Deducted: Salary:
Neither £594.04 £397.98 £82.38 £1,074.30 £929.46 £144.84
Claimant Employed £594.04 £397.98 -£790.05 £201.87 £929.46 £526.46
Both Employed £0.00 £0.00 £0.00 £0.00 £929.46 £1,578.64

In the following BBC article, it states that:


"The Green Party has pledged to introduce a Universal Basic Income by 2025, which would see every adult receiving a minimum of £89 per week."

and that "All benefits except housing benefit and carer's allowance would be incorporated into the new payments, which would be phased in over five years."

https://www.bbc.co.uk/news/election-2019-50432200



From the information currently available, it can be determined that (under UBI):
• A Council Tax allowance may not be made available to those claiming benefits.
Consequently, in the calculations below, Council Tax Support is always set to £0.00.
• Each month every adult would receive (a minimum of) £385.66 per month ((£89 x 52)/ 12).
• Although Local Housing Allowance (LHA) will be paid, the conditions under which it will be paid cannot be determined. Therefore, it has been assumed that LHA will be paid while at
least one significant member of the household is unemployed.

Universal Basic Universal LHA: CT Total Housing Residual
Income Employment Basic Support/ Benefits: Costs: Income
Status: Income: Salary Including
Deducted: Salary:
Neither £771.32 £397.98 £0.00 £1,169.30 £929.46 £239.84
Claimant Employed £771.32 £397.98 £0.00 £1,169.30 £929.46 £1,493.89
Both Employed £771.32 £0.00 £0.00 £771.32 £929.46 £2,349.96

Having calculated the Residual Income for the household associated with both benefit systems, it can be ascertained that, in all situations, the household will be more financially secure if UBI is introduced. However, when both members of the household are unemployed, although UBI would result in them having £95.03 more Residual Income each month (£239.84 - £144.84), neither benefit system is likely to elevate the household out of poverty. It is only once one member of the household starts to earn the National Living Wage (NLW) that progress can be made.

Residual Income is required to cover the purchase of food, clothes, toiletries and necessary household items. With careful budgeting, and frugal use of clothing etc, the average weekly shopping bill for two people can be brought down to about £40 per week or approximately £174 per month. Although, as above, UBI does fare better, its implementation would still only leave the household with £65.84 per month to cover eventualities. Additionally, the Housing Cost does not include household contents insurance nor does any of the expenditure include such luxuries as a Television Licence, pets, alcohol, tobacco based products, vapes or school equipment. Although contents insurance, for example, only costs (approx) £40 per year, it is still expenditure that needs to be factored in.

Consequently, it can be determined that, irrespective of the scheme used, unless a household downsizes (and downsizing costs money, plus it may not be practical or desirable to do so) or it continues to cut back on expenditure, long term unemployed households may still be "just a broken washing machine or winter coat away from disaster".

So what can be done to improve the situation?
With regard to Universal Credit, other than increasing the Standard Allowance (to the same
amount as is being suggested for UBI), a significant increase in Residual Income can be achieved by changing the way that LHA is calculated and allocated.

LHA is calculated by applying mathematical calculations to a List of Rents (LOR) obtained from a
Broad Rental Market Area (BRMA) and then taking the lower of:
• the 30th percentile of that list.
• the currently set LHA.


Using this method of calculation, LHA's are different from BRMA to BRMA. For example, the
Birmingham BRMA currently has a monthly LHA of £523.55 for a one bedroom property and
£623.30 for a two bedroom property, whereas claimants in the Coventry BRMA receive £488.67 for properties with one bedroom and £573.43 for properties with two bedrooms.

The rents listed in the LOR, however, are "net rents", i.e. they don't include any value attributed to services, e.g. school, access to public transport. Consequently, if the LOR for Category B (single bedroom) accommodation located in (say) the Black Country BMRA is examined (the Black
Country BMRA is the area bounded by the red line in the image to the right), it will be noted that they all fall within the Black Country's allocated LHA of £397.88 per month.

However, an online search for single bedroom properties, for less than £400 per month, located within a 10 miles radius of Wolverhampton reveals that (search date: 23/01/2021):
• Only 30 are available (the next lowest rental being £400 per month).
• 7 of the listed properties are house shares, i.e. they are actually classed as being LHA Category A properties.
• 3 are retirement properties.
• Nearly all would require severe downsizing if rented, i.e. they are extremely compact and lack any form of storage.

It is interesting to note that:
• Using the 50" percentile of the list would only increase the LHA by another £24.86 (to
£423.84).
• Using the 60" percentile would increase the LHA to £448.76 (an increase of £49.78 on the original LHA), a value that is far more representative of the actual rental market (68.75% of the rentals in the LOR fall within this value).


Having determined that Residual Income levels can be increased, even if only marginally, by using the 60" percentile of the LOR, the way that LHA is allocated needs to be investigated in order to determine whether or not further benefits can be attained.

LHA is allocated by Category. This means that, if a property has two bedrooms then a Category C LHA would normally be allocated. However, if a household consist of only two people and they are in a partnership, unless they can identify reasons why they need two bedrooms, the claimants will only receive a Category B (single bedroom) allowance. This reasoning is often referred to as the "bedroom tax". Obviously, as Category B LHAs are less than Category CLHAs, a significant shortfall in benefits will result and that shortfall can mean the difference between a household being above or below the poverty line.
Consequently, it is suggested that the "bedroom tax" be scrapped and that LHAs should be, as a minimum, calculated using the 60" percentile of the LOR. Not only would these changes benefit Universal Credit recipients, because LHA will be initially linked to any planned implementation of UBI, UBI recipients would also benefit. In Birmingham, these changes could result in an unemployed household receiving an additional £150 (approx).

As far as UBI is concerned, if it is to realise its aim of decreasing poverty in the UK, then:
• The amount each person receives needs to be increased to (say) £430 per month; an increase of only £30.02.
• In order to finance that increase, it needs to set an individual income threshold above which UBI wouldn't be paid. This action would dramatically reduce the amount allocated to UBI by the state (money that could be used to good effect elsewhere), would ensure
that the correct level of UBI is available to those who need it and it would avoid paying UBI
to those who didn't need it. For example, what need has someone earning (say) £3,000 per month for UBI?
• Care is needed to ensure that unemployed recipients, unless they have qualified and justifiable reasons for not doing so, actively seek employment or trial their own business.

At the end of the day, it's not the method of benefit payment that matters, it's the amount of benefit received.
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The Cost of Energy:


There is scope in the UK to reduce energy prices. For example, in 2020 in Finland, the average price paid for electricity was €0.174 per kWh (£0.15 per kWh), whereas in the UK in 2019 (and government figures show that there was a slight rise in 2020), the average price paid was £0.163 per kWh. With this comparison in mind, it is interesting to note that the Finns consider their energy to be expensive and there are calls to reduce its cost.

https://yle.fi/uutiset/osasto/news/law change could cut electricity prices by hundreds of eur os/11761762

Although there is only one pence difference between the two values, it also needs to be recognised that the average price paid in the north of England is approximately two pence higher than the average price paid in London. Why? Given the higher incidence of poverty in the northern regions of the country, the minimum target should be to standardise electricity prices across the whole country.

Even though energy provider profits have been capped, consumers are often unable to afford the price of energy and, as a consequence, a substantial number of properties go without any form of hot water and heating (I know of two such properties). In addition to the cost of energy, other underlying causes of this problem are:
• Household income: Income from employment and/or benefits is insufficiently to cover all outgoings;
• Poor or thoughtless budgeting: Cigarettes, alcohol or hobby related items, for example, will be purchased in favour of paying utility bills;
• Substandard and aging housing increases utility bills: It can cost over £150 per month (primarily gas), in the winter months to inadequately heat a Victorian, mid-terrace property that would not benefit from the application of an insulation grant, i.e. it would only benefit from being pulled down and replaced!

A Different Mindset Is Required To Become Green:


An obvious effect of the decline of Britain's coal and manufacturing industry is the reduction in employment opportunities and an increase in levels of poverty. Consequently, any strong desire to increase employment and to reduce poverty levels can only be satisfied by reversing previous industrial trends.


The Guardian article (https://www.theguardian.com/business/2019/may/22/what-went-wrong•
at-british-steel) states that the UK's steel industry alone employed in the region of 323,000 people in 1971. Yet now it only employs around 31,000 people; that is a huge drop over 50 years. The House of Commons Library paper (https://commonslibrary.parliament.uk/uk-steel-decades-of• decline/) also highlights issues associated with steel production in the UK.

Equally, The Guardian article (https://www.theguardian.com/business/2020/jan/30/british-car•
manufacturing-slumps-to-lowest-level-since-2010) discusses the cause of the decline over the last
10 years while this CBSS News article examines the longer term causes of automotive manufacture decline in the UK (https://www.cbsnews.com/news/how-the-uk-lost-its-car-manufacturing• industry/).

Although, at first glance the idea of increasing steel and automotive production in the West Midlands may be undesirable, providing that resurgence is carefully orchestrated, these industries could play an important part in West Midlands' regeneration plans. The automotive industry, for example, could subscribe to the British government's existing plans to move towards zero
emission vehicles (https://www.gov.uk/government/organisations/office-for-zero-emission• vehicles/about/research) and, as far as the steel industry is concerned, if the West Midlands assisted with the research into fossil free steel production techniques (https://www.ssab.com/company/sustainability/sustainable-operations/hybrit) steel too could, once again, become a dominant British industry without effecting the Green Party's principles.

When discussing resurgence in British industry, the following factors need to be included:
• Many disused industrial sites have now been repurposed. The Bilston Steels Works sites, for example, which had subsequently been a National Coal Board operated open-cast mine, now houses the Springvale Sports & Social Club, the Springvale Retail Park, a large housing estate and part of the Black Country Route. Consequently, there is a need to find, or generate, suitable (fully-factored urban regeneration projects would be able to identify these).
• Research into increasing productivity and costs associated with supporting industries, e.g. the production of hydrogen gas, needs to be increased.
• Rather than focussing on the production of privately owned zero emission vehicles; not just because of the desire to reduce their use, the resurgent automotive industry shou Id focus on utility vehicles, e.g. farm vehicles, commercial vehicles and buses.
• The rail industry, e.g. the production of zero emission power units, could also be included.
West Midlands CENTRIC:


Although the WMCA has established Energy Capital; a smart energy innovation partnership linked to the Energy Systems Catapult initiative, it needs to be recognised that, if the West Midland and Britain is to be rejuvenated through the application of sustainable employment and "innovative" green technologies, a fully factored and integrated approach must be adopted. That is, energy production, waste management, housing, transport, industry etc must no longer be treated and developed as individual entities; all aspects of society must be considered at the same time.

In An Easy To Use Transport Network this document identifies the effects that poor urban planning has had on the transport industry. Other areas of society, such as education and housing have also suffered from the failure to realise that society is a single entity and, as such, its requirements need to be treated as a single entity.

Even before the reform of local government practices in 1832, local authorities fought for supremacy over neighbouring authorities and, unfortunately, prestige still lies behind many planning approvals today. In today's society, there is no place for prestige or greed. Correct decisions need to be made quickly and for the right reasons - and the only right reasons are those that benefit society as a whole.

In addition to fostering the regeneration a broad range of traditional industries, the West Midlands can support industrial, new business growth and society in general by establishing CENTRIC - Centre(s) for Enterprise, Training, Innovation and Collaboration - in partnership with local universities, colleges and other businesses. Partnership with universities and colleges will
play an important part in the overall process and will ensure compatibility with the outcome of the government's "Skills for Jobs: Lifelong Learning for Opportunity and Growth" White Paper.

As its name implies, CENTRIC will be the focal point for establishing a sustainable and environmentally focused society, i.e. it will provide research and training opportunities covering such things as:
• Energy efficient and architecturally favourable building design (many people have a preference for older buildings because they are more attractive and "quirky").
• Waste management and District Heating methodologies.
• Energy generation.
• Alternative green fuels.
• Harmful emission capture and reprocessing.
• Sewage processing.
• Socially and environmentally friendly vehicle design.
• Transport methodology.
• Business start-up & Entrepreneurship.
• Increasing the efficiency, scalability and cost effectiveness of existing technologies and, above all,
• Fully-factored urban regeneration methodologies.
• Obtaining potable water from the sea. The UK is surrounded by sea yet we obtain our
water environmentally unfriendly sources such as rivers and reservoirs. Consider: where do
Malta and Goza obtain their potable water from?
• Enhancement to the fresh water production process that would remove the impurities which lead to pipe and appliance furring.
• Water reprocessing, e.g. separating water into oxygen and hydrogen. It is worth noting that recent advances have made the process far more energy efficient. There is a growing need for hydrogen to replace fossil fuels.
• CO2 capture and reprocessing, e.g. Calcium Carbonate precipitation for CO2 storage and utilization, separating CO2 into carbon and hydrogen. These techniques would replace the current "capture, store and dump" approach and help to alleviate or reduce the need to produce CO2 for the food industry.
• Alternative packaging. Consider: how did the Victorian's package and store their food and other consumables?
• Waste water/ sewage processing: https://www.clarke-energy.com/applications/sewage• gas/. Directly linked, improved CO2 capture and reprocessing techniques would benefit this process.
• As previously mentioned, advancement of hydrogen based steel production.


Innovation:


To innovate (definition): To alter or change, by the introduction of something new.
(The New Elizabethan Reference Dictionary, Second Edition, George Newnes Ltd, Peter Finch M.A.) It needs to be remembered that something that is considered to be innovative in one country or
society can be standard practice in another country or society.


Finland is renowned for producing innovative, sustainable and energy efficient solutions to a wide variety of problems; such as those identified in the link below. Therefore, it is suggested that, rather than instigating fresh research, Finland's methodologies are carefully studied with a view to learning them, using them as the basis for training programs, implementing them a quickly as possible and then researching possible enhancement. Why reinvent the wheel when it isn't necessary?


https://media.sitrafi/2017/04/21134555/World class sustainable solutions from Finland.pdf


Business Start-up & Entrepreneurship:


Although business hubs and training opportunities exist, they suffer from being too restrictive, i.e. they are focussed on one particular target group, e.g. the SPEED Project only supports students and graduates of the University of Wolverhampton looking to start a business, or they are ineffectual, e.g. existing business start-up courses are more likely to lead to a business failing within the first two years because they do not provide all of the information required and, additionally, they are completed too quickly and without adequate guidance, i.e. they aren't fit for purpose.
With regard to the latter point above, compare the business start-up training and services available from, for example, Kick Off in Business (https://www.kickoffinbusiness.co.uk/), with the entrepreneur training that is generally available in Finland (see the previous page). Although the Finnish offering needs more focus on sales & marketing strategies (including the importance of Unique Service Offers/ Unique Selling Points), the differences and problems associated with
selling products versus services, finding funding and possible business partners, the importance of
networking/ attending business events, the course's outcome is fully developed business plan, the development of which is assisted by a team of highly accessible Business Advisors.

In addition to the above, there is also a good case for dramatically enhancing the existing Business Start-up Diploma schemes offered by such organisations as Pitman Training. Although the Pitman Training offer aims to:


"ensure you (as an entrepreneur thinking of setting up your own business) have the professional skills and know-how to make the process as seamless as possible,"

unfortunately, the syllabus falls far short of the mark.


If the UK is serious about encouraging new businesses then, in additional to improving the quality and availability of business training, it needs to consider:
• The availability and quality of start-up loans, e.g. The New Enterprise Allowance Scheme.
Currently, there is too much focus on start-up loans. It needs to be recognised that, even with all the best will in the world, it can still take a new enterprise a year to become established. This period can extend to two years if the enterprise sells services rather than
products. Consequently, if there is a desire to reduce the number of 1or 2"year start-up
failures, then there is a need to pride the correct level of supportive funding. Consider the provision of the New Enterprise Allowance Scheme (NEAS) versus the support available to entrepreneurs in Finland:
• NEAS:
■ Once a business plan has been approved and an application has been submitted, applicants MAY get a weekly allowance worth up to £1,274 in total over 26 weeks.
■ £1,274 over 26 weeks is the equivalent of £49 per week or £9.80 per working day.
■ Recipients of Job Seekers Allowance (JSA) cannot claim both JSA and NEAS
funding.
■ As the NEAS information states: "£1,274 may simply not be enough to start your business. In this case you could explore other potential funding avenues, such as the government's Start-Up Loans scheme."
• Finland:
■ Providing that your business plan has been approved by a recognised Business Advisor (who has to issue a report to the employment services), you will receive a funding allocation of 33.78€ (approx £30) per DAY, or approx £150 per week (taxable), for an initial period of 26 weeks. Even after deductions, this allocation alone is over 2.5 times the UK's funding amount.
■ If there is a need, and this has to be corroborated by a Business Advisor issuing a second report), the funding period can be extended to 12 month
duration. Currently, because of the Covid-19 pandemic, an 18 month extension is permissible.
■ While in receipt of a Start-up Grant, it is also possible to continue receiving
unemployment benefit. Unemployment benefit is paid at the same rate as the Start-up grant and is also taxable.
• Taxation. Although the British tax system is favourable to the Finnish system (when
applied to, for example, sole traders -- Finnish sole traders have to pay 24% tax in advance even for a projected revenue of 10,000€), it would be worth the UK introducing a reduced liability for all forms of business during the first two years of operation and a tiered system for non-sole traders after that. This would be especially important if the Green Party were able to implement a Corporation Tax level of 24%.
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Waste Management, Energy and District Heating:


Waste management, energy and district heating have been included in the discussion on industrial strategy because:
• Direct correlation exists between the three subjects. That is, an efficient, standardised and all-encompassing waste management strategy provides a substantial amount of the fuel required to produce both energy and district heating.
• Waste management should already be a highly co-ordinated and efficient industry- but it isn't!

Throughout, the word "recycle" and its derivations should be taken as meaning a generic term that encompasses three distinctly different, but mutually compatible ("R" based) elements:
• Reuse: taking an item in its current form and using it again for the same purpose, e.g. glass milk bottles.
• Repurpose: taking an item, changing it to some degree and using it for another purpose, e.g. turning a tennis racket into a serving tray.
• Reprocessing: taking an item and turning it into something else, e.g. turning CO2 into
Calcium Carbonate or Carbon and Oxygen.

It is recognised that the UK has an aversion towards waste incinerators. However, providing that all incinerators are linked to waste to energy and heat systems, and are fitted with efficient emission capture and reprocessing technology, they become an important component of all waste management strategies. At some point, there will always be combustible material that cannot be recycled and, in all such cases, only two other alternatives exist:
• Place it in land-fill. Land-fill sites and their emissions have to be managed and, additionally, land-fill places restrictions on use of the land for other purposes, e.g. it cannot be built on.
• Pay another country to dispose of it. Shipping waste to other countries increases waste disposal costs, increases harmful emission and is a pointless exercise primarily because, in all probability, the recipient country will use the waste to fuel their own waste to energy and heat plants.

Along with many other areas of responsibility, waste management will only be fully effective upon the introduction and implementation of national policies and strategies. Local authorities cannot, on their own, enact and enforce standardised recycling strategies that have broader scope and appeal and that are likely to succeed and be of benefit to the whole of society.

The following situation serves to illustrate what is meant by this statement. Local authorities can sporadically install plastic, metal and (possibly) glass beverage container recycling points which
may or may not be used. Only national policies can incite beverage manufactures, retailers and the general public to (once again) become involved in recycling schemes whereby:
• Only 100% recyclable (reuse or repurpose) materials are used in the production of beverage containers.
• A small deposit charge is included in the price of all glass and residual plastic beverages - the details of which are printed on the beverage container.
• Recycling points are installed in shopping centres, supermarkets and other suitable retail outlets.
• The recycling points print vouchers; the value of which is determined by the deposit value of each container processed (assessed by barcode lookup), which are accepted as part payment for shopping.
• Less recyclable waste is collected from households etc because beverage containers have already been processed at the recycling points.
• Less litter is deposited.
• The need for local authorities to collect litter is reduced because others, who wish to benefit from the deposit scheme, will have collected the beverage containers already.

Waste Collection:


Currently, waste collection throughout the WMCA is a complete mess and it's no wonder that fly• tipping is rife. Someone can move 100 yards to the next street and have a completely different regime thrust upon them - identifying which authority is responsible for waste collect is also an issue. For example:
• WV14 7NA (Bilston):
• Wolverhampton postcode.
• Waste collection administered by the City of Wolverhampton Council.
• Grey bin = recycling, collected alternate weeks, e.g. week 1.
• Green or brown bin= general, collected alternate weeks, e.g. week 2.
• Purple bin= garden, collected with grey bins, February to December, cost £35.
• Bins must be available by 07:00.
• WV13 2HP (Willenhall):
• Wolverhampton postcode.
• Waste collection administered by Walsall Council.
• Grey bin = general, collected once a fortnight.
• Green bin = recycling, collected once a fortnight with the grey bin.
• Brown bin= garden, collection starts in April, cost unknown (can't find the information on the website!).
• Bins must be available by 06:30.


Additionally, too many restrictions are placed on the type of waste that will be collected and under what circumstances the waste will be collected. For example, Walsall's requirements are:
• Bins must be placed at the edge of your property.
• They will not collect bins if they are too heavy or contaminated with the wrong items.
• All rubbish, recycling or garden waste must be in the correct bin with the lid fully closed, i.e. they will not collect anything placed on top of, or beside, a bin.

And with regard to Wolverhampton Council, you can't place textiles (worn out clothing) in recycling bins. Yet it is unclear as to
whether textiles can be placed in general
bins. Situations such as these create confusion that can only be answered by contacting the council, and possibly arranging collection at additional cost, or by making the assumption that a trip to the nearest recycling centre will be needed.

This later point creates two other problems. Firstly, if you wish to use a trailer, pickup truck of van, a permit has to be obtained first and, secondly, what happens if you have no easy means of taking the items to the recycling centre - especially when it needs to be considered that "pedestrians are prohibited from carrying waste onto this site"? The answer to that second conundrum is in the picture above! [See attachment for images]

Waste collection needs to be standardised throughout the WMCA and, preferably, throughout Britain. In addition, methods need to be employed that make waste collection more cost effective (also taking into consideration the cost of clearing up fly-tipping), easier to administer and easier for everyone to understand and that help to reduce the levels of detritus found in the streets.

Even the simple remit of placing a waste bin at every bus stop would have a positive effect on the environment.

Where space allows, communal waste collection points; which utilise high capacity Molok (or similar) containers in place of individual household bins, can provide a cost effective, environmentally friendly, flexible and proven means of collecting waste (as long as the British can be bothered to use them correctly and travel a few extra yards from their front door and vandals can refrain from setting them alight).
https://www.molok.com/benefits-and-principles/ As can be seen from Molok's website:
• 60% of the container is housed underground (this saves on space, reduces odours and compacts waste),
• Emptying involves no heavy manual labour (this improves operator safety and reduces spillage),
• The containers are water resistant and durable, reduce the number of operatives required (they can be retrained for single man operation),
reduce vehicle fuel consumption and reduce CO2 emissions.
[See attachment for images]

In addition to the advantages listed above, communal waste collection points result in more efficient and cost effective use of manpower. Currently, it takes 3 or 4 collection operatives a good 5 to 10 minutes to empty (say) 30 general waste bins. In that same time, a single operative could empty the general waste containers for an entire street. The other operatives could be retrained into single operative mode, e.g. the required drivers license etc.

If sufficient Molok containers are installed, waste can be pre-sorted into:
• Bio waste: food waste, including food that has gone bad, coffee grounds, kitchen paper, fruit peels and garden waste (produces biogas, compost and heat for energy and district heating systems).
• Paper: newspapers and magazines, advertisement leaflets, envelopes etc.
• Cardboard and cartons: milk cartons, food containers, cardboard boxes (flat-packed) etc.
• Glass: bottles and jars.
• Metal: items which are predominantly metal (but not electrical items).
• Plastic: empty food packaging, detergent and shampoo bottles, plastic bags etc.
• Mixed waste: combustible items used a fuel for waste to energy and heat plants.
• Hazardous waste: fluorescent lamps, energy-saving light bulbs, broken mirrors, ceramics, chemicals etc.
• Batteries: small and large household batteries, mobile phone batteries etc, no car batteries.
• Electronic equipment: small electric or battery-powered devices and toys etc.
• Textiles: bedding, curtains, clothes, etc. Separate containers can be provided for worn and reusable items (worn textiles can be washed and used as hobby material or to make rugs).
• Shoes.


In order to satisfy a broader range of waste management requirements, the flexibility of the
Molok containers can be augmented by 10ft (563cf), key code lockable shipping containers. These would be used for other items such as furniture, domestic appliances, mattresses, used oil, car batteries, tyres etc.

With regard to what can and can't be recycled, even building rubble and porcelain can be washed, crushed and used for footpaths, as aggregate in "building blocks" (more research required) and as foundation material etc.


https://www.agg-net.com/resources/articles/recycling-waste/building-a-brighter-future-for•
recycled-a n d-seconda ry-aggregates


Recycling Centres:
[See attachment for images]

In the UK, there is a need to redefine the term "recycling centres". Such centres need to become exactly what their name implies, i.e. centres for recycling rather than places where all forms of detritus can be deposited.

To maximise the potential of all waste collected, and items collected from other sources, e.g. factories, household clearances, donations etc, large scale, not-for-profit recycling centres (that are aligned with waste collection depots and waste to energy plants) should be established. These would capitalise on and further develop existing initiatives such as those identified in the links below:
https://www.greenwastecompany.com/
https://disposalknowhow.com/reuseful-uk/

In order to gain maximum benefit, these recycling centres will need to become a highly recognisable high street brand. Rather than directly competing with existing recycling and fund raising outlets, such as those established by the major charities, the recycling centres will providesuch outlets with a free source of marketable material. Additionally, by instituting manufacturing and refurbishing workshops etc, they will provide training and employment opportunities and free handicraft materials etc for schools. An example of such an enterprise can found in the following link.

https://www.kierratyskeskus.fi/in english

Kierr~tyskeskus (Finnish for Recycling Centre) is a household name in the Helsinki Capital Region of
Finland. In addition to the main collection, manufacturing and retail outlet in Nihtisilta (in the Espoo municipality) it can be seen that they have shops in 8 different locations within the Region. Their services include:
• The collection and sorting of household items, furniture etc from businesses and scrap materials. All household items are checked for value and high value items are sold on to specialist retail outlets, such as antique shops, or sold via auction.
• The sale of reusable items: clothes, toys, sports equipment, musical instruments, bicycles, books, records and CD, electrical items etc. All electrical items are fully tested (and computers are reimaged) before resale and most electrical items are sold with a limited 3 month warranty.
• Manufacturing of handicraft materials. For example, off-cuts of upholstery material are packaged for sale and card is cut and
turned into greetings cards.
• Refurbishment of furniture and bicycles etc. Regarding bicycles, many are collected from periodic apartment building bicycle store clear-outs. Current residents are given advanced notice to identify and mark their property. Any items that aren't marked after (say) one month are collected and taken to Kierr~tyskeskus.
• Manufacturing of jewellery etc from a variety of items.
• Manufacturing of bespoke clothes from end of line material.
• Repurposing items, e.g. turning damaged drums into coffee tables, broken tennis rackets into trays and paper and cardboard into note books.
• Supporting society with training and "net revenue" finance.

The picture above shows Kierr-tyskeskus at the "Recycling Fair" in Helsinki on 25" April 2015.

The photographs below depict handicraft sales goods that I personally prepared from scrap material, including artificial flowers, while working for Kierratyskeskus as a volunteer.
[See attachment for images]

The concept of holding "Recycling Fairs" (not industry targeted expos, seminars and conferences) that are open to the general public and which allow businesses that produce recycled goods to sell their products, also appears to be innovative in Britain.

Waste to Energy & Heat:


In 2012, The Department of Energy and Climate Change (Emissions from Heat: Statistical
Summary, 13" January 2012) estimated that:


"In the domestic sector, the majority of heat related activities were from gas and electricity use (61.0 MtCO2e and 14.4 MtCO2e respectively), from a total of 86.9
MtCO2e.


This was almost entirely in relation to space heating (64.0 MtCO2e) and water heating (18.6 MtCO2e)."

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment data/f ile/140095/4093-emissions-heat-statistical-summary.pdf

On 5"February 2021, Statista published a report that identified the "Net CO2 emissions from transport in the United Kingdom (UK) 1990-2019 (lan Tiseo, Feb 5, 2021, accessed 10/02/2021). This report stated that:

"Carbon dioxide emissions from transport in the United Kingdom increased by roughly nine percent between 1990 and 2017 (2007) to 136 million metric tons of carbon dioxide equivalent (MtCO2e). Emissions from this sector began to decline in the following years,
and by 2013 had fallen to a low of 118.8 MtCO2e. Although emissions started to rise again,
by 2019 they had fallen to 120.8 MtCO2e. During this period, transport CO2 emissions fell by 3.7 percent, whilst total UK CO2 emissions experienced a reduction of 40 percent."

https://www.statista.com/statistics/311522/transport-co2-emissions-in-the-uk/

From these statistics; and it needs to be considered that emissions from domestic heating will probably have increased in the last 9 years, it can be seen that domestic space and water heating CO2 emissions are only 37.2 MtCO2e less than the total transport related CO2 emissions (82.6 boiler to electric boiler scheme, none of the political parties included domestic CO2 emission reduction in their recent 10 Point Climate Change Plans. Individual house are still being built with individual boilers and, chances are, even though this is a viable option, little action is being taken to ensure that existing gas boilers are hydrogen gas ready.

One obvious answer to the problem is to build scalable waste to energy and heat plants, in conjunction with improved waste collection facilities, and to require all new developments, domestic or otherwise, to include district heating in their design. In parallel, existing properties can either be retro-fitted with district heating or replace existing natural gas or oil fired boilers with electric boilers or hydrogen ready units.

With regard to waste to energy and heat plants, Woima Finland Oy's modular plant (see the link below) is capable of producing (from 150-200 tons of solid waste per day):
• Steam: 17 tons/ h (400C @ 40 bar(g)) OR
• Electricity: 3.3 MWe (gross)/ 2.5 MWe (net) OR
• Electricity: 2 MWe (net) and Thermal Energy 10 MWt. https://woi macorporation .com/techn ica I-solution/
What do these figures mean in reality?


A waste to energy plant, such as Rambol's plant in the municipality of Vaasa in Finland, is capable of processing 150,000 tonnes of household waste from 400,000 inhabitants annually and, while doing so, producing 15 MW of electricity and 45 MW of heat. This output satisfies the electricity demand of 7,000 households and 25 per cent of Vaasa's district heating demand.


https://ramboll.com/projects/re/vaasa wte


Vantaa hosts the largest waste to energy facility in Finland. This plant burns 374,000 tonnes of unusable waste per annum, meets approximately half of the city's annual district heat needs and
30% of its electricity demand, has reduced fossil fuels use by 40% and has reduced Vantaa's CO2
emissions by 20%. Vantaa's population is similar to that of Wolverhampton (233,775 versus an estimated population of approximately 262,000).

In all cases, harmful emissions are kept within EU limits.


A slight problem exists with this proposal, however. Most of the brown field sites that could be used for these purposes are being underutilised for poorly planned and executed housing or employment developments.

In addition to general waste, the heat used in district heating can be obtained from a wide variety of sources, e.g.:
• Bio waste (bio-mass), e.g. waste food, shredded vegetation, leaves, garden waste, farm waste etc.
• Gases, e.g. methane (land fill and bio-mass decomposition), hydrogen.
• Geothermal heat.
• Solar panels.
• Air source heat pumps.
• Waste heat captured from local industry, e.g. computer data centres.


Some of the additional benefits of using waste to energy and heat technology include:
• Increased employment and revenue.
• Reduced landfill.
• The residual "burn residue" can be used for building paths or in the production building materials.
• Recyclable metals.
• Compost and soil.


Urban & Town Centre Regeneration:


Over the years, local and national newspapers have been full of stories about urban and town/ city decline. Latterly, these stories have been replaced by a constant string of articles about urban and town centre regeneration project. More recently, however, regeneration articles have been followed by descriptions of town centre regeneration projects that have failed quite dismally - but why should this be? If so much time, effort and money has been spent on a project, why would
any regeneration project fail? The answer to those questions is quite simple: lack of foresight and
poor project planning.


If a regeneration project is to have any chance of success, the first stage of any project must be to understand why the decline occurred in the first place. If the causes of decline are not identified, it is highly likely a project will fail primarily because the causes of the decline still exist - and St Austell in Cornwall, provides an ideal research subject. Not only did St Austell town centre see progressive and avoidable decline over the years, the regeneration project, that made so many promises, failed to satisfy any of them. Consequently, attempts to regenerate the town are still ongoing.

Personal Note:


When the St Austell town centre proposals were first published, I saw straight away that, in all probability, the project would fail primarily because it wasn't attractive, it didn't provide the level of retail space required by many businesses and it didn't offer any advantages over other, already established town I city centres. At the time, I was personally ridiculed for being negative and for not considering the benefits the project would bring. Time and a failed town centre regeneration project have proved me right - although those that derided me will not admit it.


At this point, it is worth identifying that St Austell isn't the only town that has suffered from regeneration failure. The following links identify other urban and town regeneration failures or concerns:
• https://www.london.gov.uk/questions/2019/19701
• https://www.tandfonline.com/doi/abs/10.1080/00343400220137173
• https://www.taxpayersalliance.com/the failure of regeneration schemes
• https://cles.org.uk/publications/urbanregeneration-success-or-faiIure/
• https://www.pbctoday.co.uk/news/planning-construction-news/urban•
regeneration/43468/
• https://petition.parliament.uk/archived/petitions/73580
• https://g eographyfieldwork.com/u rban regeneration issuesU Kcities. htm


So what are the reasons for town centre decline? In short, the main answer is poor planning decisions and lack of vision, e.g.:
• Loss of industry and employment.
• The building of out-of-town retail centres resulting in a much lower town centre footfall.
• Large supermarket chains increasing their range of sales good in direct competition to those sold by local shops, e.g. clothes, records, books.
• Supermarkets being allowed to trade unfairly. The latter stages of Covid lockdown is a prime example of this. Although individual, small shops were not allowed to open, supermarkets being allowed to sell the products that the smaller shops sell, e.g. clothes, shoes, stationery etc.
• Councils charging for parking when retail parks provided free parking for (say) 3 hours.
• Poor transport connections.
• High business overheads, e.g. rental and business taxes.
• Poor investment.
• Changing building use from employment to housing.


Having identified why the town centres decline, there is a need to establish why regeneration projects fail:
• There is no room for expansion because town centres have become hemmed in by housing etc.
• Designs are not attractive; they do not entice visitors and, therefore, they do not increase footfall.
• Designs, and the retail outlets provide, are no different from many other town centres. As above, they do not entice visitors.
• Designs do not provide the retail space required by many large businesses.
• Designs do not provide flexible, resizable retail space.
• The range of retail outlets is too small and/ or they do not provide what customers want.
• Regeneration isn't backed up by increased employment and self-esteem.
• Transport links and parking facilities are not improved.


Fully-factored Urban Regeneration:


Having identified the causes of decline; and this requires total honesty on the part of all stakeholders and, in particular, the local authorities, a fully factored, realistic and "common sense" based regeneration project needs to be initiated.


In many cases, as has been identified in the case of Salford (geographyfieldwork.com above), the "bottom line (for any regeneration project) is providing work". Until this issue and the associated issue of poverty have been resolved, there is little point in starting anything else.

In addition to employment and poverty, as a minimum, fully-factored regeneration projects will need to consider (see also Housing):
• Making better use of available brown field sites and waste land. Currently, such sites are being under-utilised by ill-conceived housing and industrial developments. For example, in the picture to the right, this housing
development located west of Bilston town centre could have housed at least four times the number of families in low rise accommodation and increased the openness of the estate at the same time by providing more communal spaces.
• Maximising the available town centre land; especially land that is derelict, or that houses derelict or
semi-derelict properties and car parks.
• Reversing previous planning decisions that have resulted in increased road use and congestion.
• District heating provision.
• Public transport services and connections.
• Centralised Health Care services.
• Hotels and other holiday accommodation.
• Schools, library and sports facilities (consider combining use of school fields etc in order to maximise use). Sports facilities would be multi-functional, i.e., they would be flexible enough to be able to host a wide variety of sports, business and entertainment events. Equally, they would have fully size facilities so that, for example, there would be no need to build the additional stadia required by the Olympics.
• Centralising and locating industrial sites close to district heating plants so that waste heat can be collected and fed into the main system. Alternatively, either by retro-fit or including this requirement in all future designs, all industrial units should be fitted with heat exchangers and roof-mounted air source heat pumps so that all waste heat, including heat output from computer rooms etc, can be gathered and fed into local district heating booster stations. Equally, photovoltaic technology should form part of the roof structure. From the picture on the previous page, it can also be seen that energy generation opportunities are being missed.
• The accumulation of pockets of land into open spaces and managed woodland.
• Ensuring that all new developments match the character, feel and history of the local community- unless there is a specific reason not to. Many people lament the loss of old buildings, many of which have been replaced by roads or modern, characterless buildings. Facebook's "Wolverhampton in old photographs" provides many examples of comments that are pertinent to this statement.
• Ensuring that rest stop, overnight parking and ease of movement provision is made for long distance lorry drivers. Ideally, lorries and utility vehicles should have alternative ways of accessing town centres etc to facilitate deliveries. Although it is recognised that Helsinki, Finland benefits from underlying bed rock, the following Youtube video provides an
example of how the Finns evolve their infrastructure for everyone's benefit:
https://www.youtube.com/watch?v=ELSnrlOoFHE (watch from 7:40)
Town Centre Regeneration:


Here again, there is scope for major improvement. Forming part of urban regeneration projects, in addition they will consider:
• Ensuring that all loading bays, car parks, public transport interchanges and other facilities are located at basement or sub-street level.
• Buildings can accommodate the facilities required by major retailers.
• Open spaces are included.
• Road provision is kept to an absolute minimum. Carefully designed car parking will reduce the need for roads.

The following links provide examples of the kind of space savings that can be achieved if the desire is there.


https://www.myhelsinki.fi/en/see-and-do/underground-helsinki https://www.g-park.com/showcases/newsitem/10034/stockmann-helsinki Bilston:
It is known that the WMCA has plans to regenerate Bilston town centre (see the link below). Although this project is welcomed, using a piecemeal approach; such as is being suggested in the article, will only limit what could actually be achieved (and, beside, far more than 500 homes could have been delivered in the Bilston Urban Village).

https://wmgrowth.com/article/derelict-pipe-hall-site-to-be-redeveloped-as-wmca-accelerates•
regeneration-in-bilston-and-other-town-centres


The Pipe Hall mentioned in the article is located to the extreme right of the highlighted area in photograph below. As can be seen, it is surrounded by derelict and semi-derelict land which will also form part of regeneration process. However, it needs to be identified that the provision of housing {Pipe Hall and the old Royal Mail Office site), does not constitute town centre regeneration, i.e. it does nothing to attract people to the town from elsewhere.
project that would include district heating provision. Essentially, at the top of the area, other than a few shops, a doctor's surgery and a public house (which could be retained, the area contains Bilston Market (building and open area and the bus station (which was opened in1991) and the Metro line (located between the Pipe Hall building and the bus station).

Bilston Market could be moved to new, multi-story accommodation that would utilise the Pipe Hall site and surrounding land and the area over the Metro line, i.e. the Metro station would be underground. The Market building, externally, would be Victorian or Georgian in appearance and, internally, would be designed to attract visitors, i.e. it would be elegant rather than purely utilitarian.

The photographs to the right and below show what could be achieved. They are of Van ha Kauppahali (Old Market Hall) in Helsinki. This building attracts visitors to it so, consequently, the market traders benefit from increased footfall.
[See attachment for images]

Once the market has been moved, the freed space could then be used to develop the low-rise facilities that are listed above. The design of these buildings would also reflect Bilston's heritage (see the front elevation design under Housing). Further space could be gained by placing the bus station and car park facilities underground. The underground bus station would be directly linked to the Metro station and could, conceivably, be located directly below the existing bus station.

See also Reclassification of Green Belt and Recreational Land.

An Easy To Use Transport Network:

Apart from the Transport for West Midlands (TfWM) network being poorly planned, confusing and overly complex, inflexible, disjointed, inconsistent, swindling (try buying a Day Saver ticket on a
bus when you only have a £5 or £10 note available and the bus doesn't accept card payment!),
inadequate, uncomfortable (particularly the tram line between Bilston and West Bromwich) and unavailable (in terms of service provision and thee purchasing of tickets and travel cards), the service is adequate!

Given the nature of that opening statement, it is probable that TfMW would feel affronted by its contents and wish to understand why those comments have been made. The discussion points set out in this section are, in part, aimed at providing that understanding and, in part, aimed at providing simple and cost effective solutions to the underlying problems. However, as a precursor, it is felt that any ticketing system that allows a passenger to purchase, on the outward leg of their journey, a return ticket between Bilston and Wolverhampton from one of two bus operators that service a particular route, that cannot then be used on any other alternative route, metro or bus, for the return leg of their journey, is not fit for purpose.


The Decline in Bus Usage:


The Independent Transport Commission's (ITC) report on bus usage ("The shape of changing bus demand in England, Le Vine & White, January 2020) specifically looks at the decline in bus usage (since 2009) and sets out to indentify why that decline may have occurred. Unfortunately, however, although it provides some insight into the decline; which actually reversed in the West Midlands in 2020, it is unable to provide any concrete reasons for this occurrence. The main cause
this anomaly is research's propensity towards gathering statistics that are not substantiated by the simple remit of asking the question "Why?"

A case in point is the recent TfWM Online Community's "Getting to know you more" questionnaire. Although it asks questions such as "do you have access to a car", "would you use a mobility incentive scheme" and "do you have a SWIFT card", it does not provide any means of clarifying the responses. Consequently, although they can determine the number of respondent who don't have a Swift cards, they have no way of knowing why those respondent don't have a Swift card - and, in this type of research, knowing why something occurs is as important, if not more important, that knowing how often it occurs.

When asked about this situation, Mustard Research; who are conduction the research on behalf of
TfWM, responded that:


"(they've been conduction research with the general public for over 30 years, so everything (they) do, every method (they) use, every question (they) ask (and how (the) ask it), is deeply grounded in robust methodologies that (they've) tried and tested over the years."


In the conclusion to the ITC report they comment that:


"The findings from this report have indicated some of the ways in which the bus market in England is changing. We recommend that further work be undertaken on the views of bus users to understand what they are seeking from high-quality bus services, and to understand how bus marketing should be updated."

Here again, although it is easy to research peoples' views, the results will still be limited unless they ask that simple question. As has been said before, if the same methodology is always used, chances are, it will always result in the same or similar answer being obtained.

From a passenger's perspective, and the results of ITC's research, what could be and what is contributing to the decline in bus use? Amongst others factors, the ICT report identifies that:
• Concessionary travel for pensioners initially boosted bus travel in 2009 but, in more recent years, this aspect of use has seen a decline (Paragraph 2.5).
• Private Hire and taxi usage hasn't been a major influencer - although it does provide a door-to-door service (Paragraph 2.6).
• Shopping, leisure, commuting and education are the most common reasons for using buses. The increased trend towards the use of online shopping services may be contributing to the sharp decline (25% since 2009) in bus use. Additionally, this decline could be associated with the trend towards out-of-town shopping centres that are served by infrequent, non-existent or inconvenient bus services (Paragraph 3.3). It is also worth noting that there has been an increase in car usage amongst those who traditionally use buses, i.e. women for shopping trips.
• Bus use decline is steepest amongst lowest income groups. This may be because these groups are able to purchase and run cars (at an increasingly lower cost than public transport) and then maximise post-purchase use (Paragraph 3.6).

From a passenger's perspective, (within the TfWM area) factors include the transport network being:
• Poorly planned. The rail network is divided into 5 zones (why 5?), the bus network operates a confusing array of zones and the tram network cuts right through the middle of them all.
• Confusing and overly complex. When purchasing tickets decisions have to be made about which of 32 travel cards is needed, which service operator will be used, where to purchase those tickets and which website should be used etc.
• Inflexible. If a Swift Card is purchased for use on one part of the network, it can't be used elsewhere. If you have an "older persons travel pass", it has limitations in use (unless these have been lifted over Christmas or during the Covid-19 pandemic in order to be vaccinated) which means that a standard travel card is also required if they still work or wish to travel outside of the restricted times.
• Inconsistent:
• On TfMW's website (www.tfmw.org.uk/operations/bus-services), it clearly states that "(they) run the English National Concessionary Scheme (NCS) for the region's over-60s and disabled" yet, on the West Midlands Network websites (www.networkwestmidlands.com/tickets-and-swift/discounts-and-free-travel• passes/older-persons-pass/) it states that "You can get a pass for free bus travel
anywhere in England when you reach the female State Pension age". However, the
NCS stipulates "over 65"; not "over-60s" or "reach the female State Pension age". Additionally, it needs to be recognised that, in the Transport for London travel area, "if you're 60 or over and live in a London borough, you can get free travel on our transport services."
• Further confusion with regard to concessionary elderly travel has evolved as a result of the publication of State Pension age timetable which was introduced by the 2010 to 2015 Conservative and Liberal Democrat coalition government. If individuals are not aware of the NCS, they may well wait until they have retired; which now varies for both men and women, before applying for concessionary travel.
• There is more pressure on the elderly to work beyond State Pensionable age and more elderly chose to work beyond State Pensionable age.
• The Network West Midlands website also states that, with a Senior Rail Card, those aged 60 and over can save a 1/3 off rail fares to travel across Britain.
• Ticket prices vary, for the same product, across the different transport operators.
For example, a Low Fare Zone (Walsall, Sandwell and Dudley) adult 1 day ticket costs £3.20 yet an Nbus, all bus operator, 1 day ticket costs £4.80 and a National
Express West Midlands/ Coventry Adult Daysaver costs £4.60.
• Swindling:
• Currently, individual bus tickets, e.g. Day Savers, return tickets, can only be purchased on entry to a bus. If a passenger does not have the correct money for the fare, no change is given - even for a £5 or £10 note!
• When Return Ticket is all that is required, i.e. a passenger does not need to travel on public transport more than twice in a day, they have to purchase a Day Saver ticket. This is especially the case on the tram/Metro during peak travel times.
• Uncomfortable. Riding on the fast section of the tram line between Bilston and West Bromwich is like riding on a roller-coaster. This section is not suitable for anyone who suffers from travel sickness. Additionally, bus seats do not provide enough leg room for the average person.
• Inadequate and impractical:
• Total lack of individual and seasonal ticket purchase facilities.
• Ease of access and use for disabled passengers or passengers with pushchairs etc.
• At times when greater use of public transport should be being encouraged, e.g. during rush hour, ticket pricing is increased.
• Journey times exacerbated by road congestion.
• It does not always support unsocial travelling hours, e.g. someone who starts or ends work at 06:00.
• It is not always available and suffers from poorly conceived planning approval, e.g. a
31 minute walk is required, from either Brewood or Coven Post offices, if someone works at the industrial site at Four Ashes in Staffordshire.
[REDACTED- GDPR]
In connection with this, TfWM's own guidelines for bus service access stipulate that:


"The maximum desirable walking distance to bus services in continuously built-up residential areas is 400 metres between the hours of 7am and 7pm Monday to Saturday (two journeys per hour), and 700 metres at other times (one journey per hour)."

Consequently, it can be identified that many routes do not conform to TfMW's own requirements.
The Way Forward:


Above all, if there is a genuine desire to improve public transport in the Black Country and WMCA, then all the local authorities, TfWM and the WMCA need to start singing from the same hymn sheet. There is little point in all the individual authorities carrying out the same research that is currently being undertaken the other stakeholders and then doing their own thing.

Although it was evident to many at the time, it is now apparent that poor planning decisions; those associated with out-of-town shopping centres in particularly, have had a negative effect on town and city centres and, as indicated in the ITC report, the use of public transport and public transport journey times. Consequently, it can be concluded that, in order to increase public transport use, reduce private car use and congestion, there is a need to reverse many of the planning decisions that have lead to these problems arising. Therefore, it is imperative that such factors are included in urban and town centre rejuvenation plans. There is little point in building new town centres if, as is the case at present, nobody has any day-to-day need to go there.

The following are helping to increased journey times:
• Congestion (as above) which is also exacerbated by charging more for peat time travel.
• The need to purchase tickets on entry to buses.
• The need for disabled persons, and those accompanying pushchairs, to use the same door as everyone else.
• Only having one door in each bus - those waiting to board have to wait for those alighting.


The issues can be overcome by:
• Dispensing with the peak and off-peak pricing system.
• Making ticketing more accessible and easier to use.
• Changing to 3 door bus design (which is depicted quite negatively in the following article). https://londonist.com/london/transport/new-routemaster-buses-front-door-only
The picture on the right depicts one of the busses in service in Finland's capital region. The front door is used for boarding and alighting by the elderly and those with minor disabilities. The centre door is primarily used for disabled and pushchair access (there is sufficient room to house 3 pushchairs side-by-side). As such, it has the extendible ramp, backed up by adjustable suspension, found on most modern busses. The rear door is used for alighting only.
Both the front and middle doors have travel card readers adjacent.


To overcome the problem of fare-evading; and these are effective:
• Other passengers will actively confront anyone who has not paid.
• The bus driver will not move if they suspect that someone is attempting to evade paying, actively confronting them if the need arises.
• Public transport operators employ a team of highly active and highly effective ticket inspectors. However, in addition directing customers to purchase the required ticket, they also issue an on-the-spot fines of 80€ and, if no ticket has been purchased, instruct the offender to leave the mode of transport.

https://yle.fi/uutiset/osasto/news/ticket inspection crackdown reduces railway fare dodgers/1
0150849


To avoid contradictory information from being published, and to aid passenger interaction, the TfMW, the West Midlands and other associated websites, e.g. those operated by the individual bus operators, need to be consolidated into a single source of information.

The website should provide ticketing information, a simplified "route planner" that is able to identify all alternative routes (it is possible to obtain a route plan with only one option: walk!) and an interactive map that allows bus routes to be clearly identified.

The link below provides access to Helsingin seudun liikenne's {HSL) / Helsinki Regional Transport's
{HRT) customer oriented website. To evaluate the route planner, enter:
• Origin: Roihuvuorentie 20 F
• Destination: Helsinki-Vantaa and select "Helsinki-Vantaa Airport T1-T2 Corridor, Vantaa" After evaluating the results, set the departure time to 23:00.
Additionally, change the destination to "Suomenlinna, (liikenne), Suomenlinna, Helsinki".


It is interesting to note the speed of operation (given that the results are coming from Finland) and how easy it is to identify the alternative routes and, by selecting any of the options, the type and costs of the tickets required. Clicking on the map icon (to the right of each stage) will result in the map zooming in to provide a more detailed view.

If the map is zoomed out, it is possible to see the extent of the HSL travel zones. Plans are currently in place to include the municipalities located above the "C" zones int he region so that the two existing "D" zones become a single continuous zone.

Reduce the number of circular zones to 4 (is there a need for 5 zones?) and align all services to those zones (currently, all three modes of transport use different zoning). The minimum number of zones included on any ticket will be two. Consequently, this will produce the following zone options (when "A" through "D" is used for zone identification):
• AB, ABC, ABCD.
• BC, BCD.
• CD.

Optionally, single zone operation could be included if passenger number justify this. However, doing so could make zone selection displays more complex.
Introduce a new ticketing system (overview):
• All tickets to be valid on all modes of transport (buses, trams, trains etc) irrespective of the transport operator's area of operation.
• Introduce a non-season ticket time limit on all tickets which ends after a passenger has boarded a mode of transport. This means that a passenger can change between modes of transport while the time limit is still operable, If the time limit expires just before a passenger boards another mode of transport, then another ticket will need to be purchased. If, on the other hand, one minute of the time limit remains after a passenger has boarded, the ticket will still be valid for the entire segment of the journey.
• Standardise ticket prices which, as above, dispenses with peak and off-peak pricing, i.e. a standard fare should be used irrespective of the time of day.
• Install card readers in all modes of transport and at entry points to tram and railway stations.
• Reduce the number of primary travel cards (including Apps) to two:
• Residents (lives in the TfMW travel area) with two modes of operation:
• Seasonal, pre-selected zones, e.g. AB.
• PAYG, travel zones selected on entry to transport method - or at railway stations if readers cannot be installed in all train carriages.
• Available from service centres and all manned bus stations.
• Available as a mobile app.
• Using the PAYG function, card holders can pay for additional passengers.
• Visitors - seasonal (1 day to 1 month), pre-selected zones only.
• All travel cards to support concessionary operation - if proven at the time of purchase.

Ticket Purchase:

It will always be the responsibility of the passenger to ensure that they have a valid ticket prior to embarking on any stage of a journey.

Resident travel cards will only be available from main travel service centres, e.g. at ALL bus and railway stations. Proof of residency, e.g. a person's PIN(!!!) will be required. The storing of a person's PIN on the travel card will remove the need to produce photo-cards.

Visitor cards will be available to main travel service centres and all PayPoint outlets (including those located at airports).

Ticket machines will need to be installed at all bus and railway stations and at key transport interchange locations. Ticket machines will provide a means to:
• Purchase season tickets - that takes into consideration any remaining season ticket time on the card.
• Top-up the PAYG function of residential travel cards. The remaining PAYG balance should be displayed each time the card is used.
• A means to purchase single use tickets.

Season tickets can be purchased at main travel service centres, by using standing orders or via online top-up services.
Exceptionally, single use tickets can be purchased from bus drivers (but not tram drivers). Where a passenger does not have the exact money, a ticket voucher covering the over-paid amount will be printed along with the ticket. Buses should have contactless payment facilities.


Although the suggestions outlined above can be used by any of the individual and combined local authorities, greater passenger benefit and local authority cost savings would be achieved if the same system was used nationally. A national travel card, for instance, would allow someone to travel from (say) the south-west of England to Newcastle and to make use of the local public transport network- even if in PAYG mode. Currently, and for the foreseeable future, that is not possible.


Overcoming Vandalism:


Means of overcoming concerns about ticket machine vandalism include increased police street presence (full time constabulary and volunteer special constabulary) and the use of fully trained and paid security officers - such as those used extensively in Finland (see below) - who have powers of arrest.

Although the focus here is on reducing vandalism, increasing the number and visibility of security officers results in additional benefits, particularly when they carry out regular patrols (such as regularly occurred in the UK in previous years:
• Enforcement of laws.

• Safer communities, shopping centres and public transport services.

• Crimes can be responded to quicker/ reduction in criminal activity.

• Minor anti-social behaviour offences can be prevented or dealt with quicker.

• Enforcement of discipline and respect.


Notwithstanding this opinion, a broader range of issues need to be considered. https://www.police-foundation.org.u k/2017/wp-content/uploads/2017/06/foot patrol.pdf

Reclassification of Green Belt and Recreational Land

Fundamentally, I object to the reclassification of any green belt and/or recreational land for any other purpose, including the building of homes and/or employment premises. My reason is that this reclassification is not required because of the extremely high incidence of empty, under• utilised, semi-derelict and derelict properties and land in the Black Country and WMCA areas.


Although it is appreciated that the Black Country Plan identifies a large number of brown field sites that can be utilised for homes and employment, and a further number of planning application
have been granted for the repurposing of sites and buildings, other sites exist that do not appear to have been identified. No reallocation of land should take place until there is no alternative. Equally, company profits should not be considered to be more important than open green spaces.


If time was taken to walk around the Black Country, rather than drive, such premises and land can be easily identified and, with regard to under-utilised land, examples readily stare us in the face. The following is a prime example.


The picture to the right, courtesy of Google Maps, depicts part of the Springvale Way Retail Park in Bilston. From this picture, the following can be easily identified:
• Only four employment premises are represented: B&Q, Halfords, Matalan and Mecca Bingo.
• The area of land utilised for access roads, delivery and car parking far exceeds that used for buildings.


Aspects of land use that cannot be easily identified from this picture are:
• The staged use of the available car parking - particularly in
respect of Mecca Bingo (predominantly open from late morning until midnight).

• B&Q have attempted, and still are attempting, to block off the north-easterly end of (their)
car park (take a line from the north-easterly end of the retail building across the car park) to reduce instances of the car park being used for "recreational activities" and vandalism, fly tipping and arson.
• Some areas do not appear to be utilised at all, e,g, the area immediately adjacent to the north-easterly end of the B&Q premises.
(See attachment for images)
This land could have been better utilised by:

• Building a single, possibly, three story premises that housed B&Q and Halfords on the ground and middle/ mezzanine floors and Mata Ian and Mecca Bingo on the upper floors.
• If surface level car parking and deliver bays were required, a single area, serving all premises, would have sufficed.
• Placing all of, or a majority of, the car parking under the premises and using high capacity goods lifts, stairs and escalators to provide the necessary customer access. This would have freed land for other employment purposes.
• Placing all of the delivery bays beneath the premises and using high capacity goods lifts etc to provide access to stock rooms and the sales floor.
• The retail outlets providing prompt, same day/ within 2 hours delivery services. This would allow greater use of public transport. Please note that I walk from my home address to this retail park in order to visit all three retail outlets. I either carry home my purchases, even
2.Sm lengths of 60cm wide furniture board, or organise transport if a product is too cumbersome or heavy.


Examples of land which could be readily assigned to housing and/or employment are often less obvious. However, they include (currently these cannot be found in the Black Country plan):
• The former Babcock Transformers site on Oxford Road, Bilston. From the aerial picture (to the right- see image for attachment), it is obvious that this site has been derelict for some time. In addition to this site, other buildings along this section of Oxford Street into High Street, Moxley appear to be under-utilised or empty.
• The derelict public house in Newbolt Road, Bilston. From the aerial picture of this site (below right- see image for attachment), it can also be determined that this site has been derelict for some time and, in addition, is used for fly-tipping. Other issues that can also be identified are the large number of gardens that are left to go derelict, particularly the row southeast of the public house, or that are only used as dumping grounds. Both of these issues need to be avoided if the current high levels of rat infestation in the area are to be reduced.
• The empty public house/ restaurant at the junction of Moseley Road and Bilston Road, Bilston.
• The unfinished building plot on the corner of Bilston Road and Darlaston Lane, Bilston. The building of four premises has been started but they remain unfinished.
• The Spread Eagle public house/ Chill Spot and The Imperial Banqueting Suite, Litchfield Street, Bilston.

Generally, there is a need to re-evaluate how we allocate land to housing, employment and town regeneration projects. Greater vision and forward thinking is required if the country is to achieve, for example, the levels of housing required, without utilising even more valuable green spaces. It isn't difficult but, if land use is to be maximise, a co-ordinated approach to future development need to be taken.


Throughout this document, reference has been made to Finland and its approach to resolving the same issues that exist in the UK and, this reference stems from experiences gained while living in that country for over six years. One example of Finland maximising land use, while still providing the infrastructure required, is Kamppi Centre in Helsinki. The following links provide information on this project and, while reviewing the Wikipedia link, it is worth noting just how much of the facility is located underground.


https://en.wikipedia.org/wiki/Kamppi Center


https://finnisharchitecture.fi/kamppi-shopping-centre-and-public-transport-terminaI/

With regard to the underground bus terminal, its size can be determined from the following video
(the departure gates are on the right hand side between the yellow and red marked pillars). https://www.youtube.com/watch?v=uMFAObGe88w

Object

Representation ID: 21191

Received: 11/10/2021

Respondent: Mr John Embrey

Objection to Black Country Plan in General and please see attached sheets for objections to 1 site in particular.

Support

Representation ID: 21238

Received: 11/10/2021

Respondent: Newlands Developments

The Vision, Strategic Objectives and Strategic Priorities (Section 2)
The Vision
The Black Country Authorities have set out a vision for the Black Country up to 2039. We support the vision, in principle, which seeks to create a prosperous, stronger and sustainable Black Country. This vision provides a positive framework for the Strategic Objectives and is generally aligned with the three overarching sustainability objectives set out in NPPF Paragraph 8.

Strategic Objectives
We have reviewed the strategic objectives and strategic priorities set out in Table 1 (Black Country Plan – Objectives and Strategic Priorities) of the draft Plan. We are supportive of the Strategic Objectives, which will address the key strategic challenges and opportunities that have arisen since the Core Strategy was adopted in 2011, particularly in relation to climate change, health and wellbeing, promoting sustainable transport, enhancing the natural and built environment, and meeting infrastructure needs It is considered that an employment development at the Site would align with these Strategic Objectives, especially Strategic Priority 7, which aims to provide a balanced portfolio of employment sites and to protect and enhance existing sustainable employment areas to support the development of key employment sectors and enable existing businesses to expand. We consider that the Site, which has the capacity to deliver an employment (industrial and/or logistics) development of up to 11.2 hectares in a sustainable location, would assist the Black Country Authorities in achieving this Strategic Priority and would support the diversification of the Black Country economy.

Comment

Representation ID: 22504

Received: 11/10/2021

Respondent: Environment Agency

Chapter 2 : The Black Country 2039: Spatial Vision, Strategic Objectives and
Strategic Priorities

The Vision of ‘Creating a prosperous, stronger and sustainable Black Country’ implies an area that is environmentally and economically resilient, not only adapted to Climate Change impacts, but that is robust to other events such as the Coronavirus Pandemic. A Circular Economy, that minimises residual waste, and maximises the economic potential of waste, should result in reduced carbon impacts and increased economic gains, by retaining resources where they can be recovered and put back into positive use, such as in manufacturing or organics in farming. A Circular Economy can support all the 8 Objectives, where waste becomes less of a ‘problem’ and more of a positive
opportunity. This point is perhaps not made as clearly as it could be in Strategic Priority
13. Additionally avoiding sending waste to landfill should not imply the alternative of burning it, as this causes carbon emissions.

Strategic Priority 2 also refers to maximising the use of low carbon energy solutions.
We need to identify ‘low carbon’ options for managing waste, including replacements for traditional Waste to Energy facilities, or possibly their modification to capture and utilise carbon.
The Duty to Cooperate also applies to Waste Management Planning, not just Housing and Employment. As in our letter of 8 September, 2017, we need to ensure that there is no conflict between adjacent developments, specifically residential areas and industrial/waste activities. Strategy 6 says: ‘To provide a built and natural environment that protects health and wellbeing through minimising pollution (air, noise and other forms), providing healthy homes…’ Therefore we need sufficient safeguarding for existing and new waste activities, with application of the NPPF ‘Agents of Change’ provision in the Plan, and with recognition that excessive housing encroachment near waste and other activities can impact negatively on resident’s amenities and wellbeing, including deprived and disadvantaged areas. Additionally, expansion in housing also means an increase in waste volumes produced, with consequent demand for more waste handling capacity, and waste transport can also contribute to both poor air quality in communities and wider carbon emissions, so we need to reduce ‘waste miles’, which requires more and/or larger local facilities for waste.

In short, waste can play a big role in delivering multiple solutions, -if we change how it is both viewed and treated. This probably requires a more integrated approach to infrastructure than has previously been considered, with waste often being dealt with as a largely separate planning issue.

Figure 2, (the Key Spatial Diagram), does not specifically show any existing or planned strategic waste capacity in the context of other proposed infrastructure and this should be rectified.

Comment

Representation ID: 22621

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

Black Country Plan Draft Plan Regulation 18 Consultation: Preferred Options



Formal Representations on behalf of the Chief Constable of West Midlands Police.



We act for the Chief Constable of West Midlands Police (CCWMP) and are instructed to
make representations on local development documents in respect of securing policy
reference in such documents to matters including:

• Recognising the community need for securing safe environments with crime
reduction made a priority;



• Requiring developers to demonstrate how proposals address community safety
and crime prevention in Design & Access Statements, or other relevant planning
application documents;



• Promoting a safe and secure entertainment, leisure and evening economy;



• Ensuring the timely and effective engagement of the police and other emergency
services to ensure effective delivery of infrastructure projects required as a result
of development growth with the recognition that the police are a social
infrastructure delivery agency;



• In appropriate cases, seeking financial contributions towards the additional
expenditure burden placed on West Midlands Police as a consequence of
development proposals and growth;



• Ensuring the timely and effective engagement of the police and other emergency
services in the planning processes in relation to matters likely to affect crime and
fear of crime; and Ensuring the timely and effective engagement of the police and other emergency
services in relation to Counter-Terrorism matters. For example, Counter
Terrorism Security Advisors can give appropriate advice concerning Vehicle-
Borne Devices (VBD) mitigation and the Crowded Place agenda (particularly in
relation to shopping areas and the night-time economy).



Section 17 of the Crime and Disorder Act 1998 states, ‘Without prejudice to any other
obligation imposed on it, it shall be the duty of each authority to which this section
applies to exercise its various functions with due regard to the likely effect of the exercise
of those functions on, and the need to do all that it reasonably can to prevent, crime and
disorder in its area’.



The CCWMP clearly has a statutory duty to secure the maintenance of an efficient and
effective police force for its area and, of course, the Council is also statutorily required to
consider crime and disorder and community safety in the exercise of its duties with the
aim of achieving a reduction in crime.



The CCWMP is grateful for the opportunity to comment on the Draft Black Country Plan
(BCP).



To avoid repeating the background information on each BCP Comment Forms we
formally request that this letter is read in conjunction with each and every one of
the submitted Comments Forms.



Comments Forms are submitted on the following Policies:



• CSP4 Achieving well-designed places
• CSP5 Cultural Facilities and the Visitor Economy
• HW1 Health and Wellbeing
• HOU4 Accommodation for Gypsies and Travellers
and Travelling Show people
• HOU6 Houses in Multiple Occupation
• CEN1 The Black Country
• ENV7 Canals
• ENV9 Design Quality
• DEL1 Infrastructure Provision



(Please note: the Comments Form does not provide the option of ticking a box to support
aspects of a policy and object to other parts/omissions in the policies. We have therefore
generally ticked the ‘object’ box on the form, but it is important to emphasise that the
CCWMP welcomes many aspects of the emerging BCP.)



A summary of the support and objections is also reproduced within this letter for
completeness and ease of reference.



In addition, a copy of a letter dated 9th July 2020 (with appendices), submitted on behalf
of the CCWMP to the four Black Country local planning authorities is resubmitted with this
letter to form part of the current response to the Regulation 18 consultation. The letter
sets out the need for developer contributions towards Police infrastructure and provides background information in support of the representations submitted to Policy DEL1
‘Infrastructure Provision’ in the Draft BCP.



Background Relevant to, and to be read in
conjunction with, all Comments Forms
submitted on behalf of the CCWMP



Planning Policy



National Planning Policy Framework, July 2021


1. The National Planning Policy Framework (NPPF), July 2021, paragraph 2 states that
the NPPF must be taken into account in preparing the development plan and is a
material consideration in planning decisions. Planning policies and decisions must
also reflect relevant international obligations and statutory requirements.



2. Paragraph 7 explains that the purpose of the planning system is to contribute to the
achievement of sustainable development. Paragraph 8 identifies three overarching
objectives for the planning system: an economic, social and an environmental
objective. These objectives include identifying and coordinating the provision of
infrastructure and fostering a well-designed and safe built environment to support inter
alia communities’ social well-being. Paragraph 9 states that these objectives should
be delivered through the preparation and implementation of plans.



3. It is noteworthy that the July 2021 revisions to the February 2019 NPPF include a
change to the wording of paragraph 11 giving greater prominence/emphasis to the
need to ‘align growth and infrastructure’ when plan-making.



4. Paragraph 16 of the NPPF confirms that Plans should be prepared with the objective
of achieving sustainable development and should be shaped by effective engagement
between plan-makers and local organisations and statutory consultees.



5. Paragraph 35 of the NPPF states that Local Plans are examined to assess whether
they are ‘sound’, which necessitates an evaluation to determine whether they have
been positively prepared, justified, effective and consistent with national policy. In
terms of whether a plan is justified, they should be based on proportionate evidence.



6. Chapter 8 ‘Promoting healthy and safe communities’ identifies at paragraph 92 that
planning policies and decisions should aim to achieve healthy, inclusive and safe
places, which are safe and accessible, so that crime and disorder and the fear of
crime do not undermine the quality of life or community cohesion.



7. Paragraph 96, introduced in the revised 2021 version of the NPPF, explains that to
ensure faster delivery of other public service infrastructure including criminal justice
accommodation, local planning authorities should work proactively and positively with
promoters, delivery partners and statutory bodies to plan for required facilities and
resolve key planning issues before applications are submitted.
8. Paragraph 97 states that planning policies and decisions should promote public safety
and take into account the wider security and defence requirements. This should be
achieved by:

a) anticipating and addressing possible malicious threats and natural hazards,
especially in locations where large numbers of people are expected to
congregate. Policies for the relevant areas (such as town centre and
regeneration frameworks) and the layout and design of developments, should
be informed by the most up-to-date information available from the police and
other agencies about the nature of potential threats and their implications. This
includes appropriate and proportionate steps that can be taken to reduce
vulnerability, increase resilience and ensure public safety and security; and



b) recognising and supporting development required for operational defence and
security purposes and ensuring that operational sites are not affected adversely
by the impact of other development proposed in the area



9. Paragraph 130(f) states that planning policies and decisions should ensure that
developments, amongst other requirements, create places that are safe, inclusive and
accessible and which promote health and well-being, with a high standard of amenity
for existing and future users; and where crime and disorder and the fear of crime do
not undermine the quality of life or community cohesion and resilience.



10. Paragraph 134 emphasises that development that is not well designed should be
refused, especially where it fails to reflect local design policies and government
guidance on design.



Planning Practice Guidance



11. The national ‘Planning Practice Guidance’ (PPG) is updated on a rolling piecemeal
basis to reflect policy and legislative changes. In the context of design, the PPG,
revised October 2019, Paragraph:001 reference ID: 26-001-20191001 states that
well-designed places can be achieved by taking a proactive and collaborative
approach at all stages of the planning process. To be read alongside this guidance,
The National Design Guide sets out the characteristics of well-designed places and
highlights in the section entitled ‘Public Spaces’ that well-designed places should feel
safe and help overcome crime and the fear of crime.



12. Paragraph: 001 Reference ID: 26-001-20191001 reiterates that paragraph 130
(renumbered to paragraph 134) of the NPPF sets out that permission should be
refused for development of poor design that fails to take the opportunity of promoting
healthy and safe communities.



13. Paragraph: 004 Reference ID: 26-004-20191001 confirms that non-strategic policies
can be used to establish more local and/or design principles for an area, including
design requirements for site specific allocations.



14. The PPG also includes a section entitled ‘Healthy and Safe Communities’, which emphasises that planning provides an important opportunity to consider the security
of the built environment, those that live and work in it and the services it provides.



15. ‘Supporting Safe Communities’ Paragraph 009 Reference ID: 53-009-20190722,
revised July 2019, highlights the importance of Section 17 of the Crime and Disorder
Act 1998 (as amended) which requires all local, joint and combined authorities to
exercise their functions with due regard to their likely effect on crime and disorder and
do all they can to prevent crime and disorder. Crime for these purposes includes
terrorism. It explains that planning provides an important opportunity to consider the
security of the built environment, those that live and work in it and the services it
provides.



16. Paragraph: 010 Reference ID:53-010-20190722 sub-titled ‘How can planning help to
achieve resilient places?’ states that good design that considers security as an
intrinsic part of a masterplan or individual development can help achieve places that
are safe as well as attractive, which function well and which do not need subsequent
work to achieve or improve resilience. However, good security is not only about
physical measures and design; it requires risks and mitigation to be considered in a
holistic way.



17. The PPG highlights that local authorities may find it helpful (either through decision
taking or plan making) to undertake a Security Considerations Assessment (SCA), or
to take into account a SCA process undertaken by developers and other applicants
as part of the design of new developments. A SCA is a mechanism by which
organisations can demonstrate, through a fully documented process, that potential
security-related vulnerabilities have been identified, assessed and where necessary,
addressed in a manner that is appropriate and proportionate (Paragraph: 010
Reference ID: 53-010-20190722).



18. The PPG confirms that good design means a wide range of crime from theft to
terrorism are less likely to happen by making committing those crimes more difficult.
It helps create safer places, infrastructure and buildings that are less vulnerable to
terrorist attack and should an attack take place, where people are better protected
from its impacts (Paragraph:010 Reference ID: 53-010-20190722).



19. The PPG also states (Paragraph: 011 Reference ID: 53-011-20190722) that for all
locations which will generate crowds in public places, applicants and local planning
authorities should consider appropriate security measures in the design of buildings
and spaces. Good counter-terrorism protective security can also support wider
prevention. The PPG identifies a number of sources of guidance in this respect
including ‘Protecting Crowded Places: Design and Technical Issues’, which refers to
‘Secured by Design and ‘Safer Parking’ standards.



(https://www.gov.uk/government/publications/protecting-crowded-places-design-
and-technical issues)



20. Paragraph: 011 Reference ID: 53-011-20190722 also states that the consideration of
security requirements will need to be proportionate to the size and nature of the
development, the anticipated number of users and the wider setting. As well as understanding the purpose of the site, how it will operate and its potential to be
regularly crowded, consideration will need to be given to the measures that directly or
indirectly mitigate identified threats as far as is proportionate. This could include
protection of the public from vehicles used as weapons or as an Improvised Explosive
Device.



21. In terms of Plan making, Paragraph 042 reference ID: 61-042-20190315 (March
2019) provides that in evidence gathering, strategic policy-making authorities where
appropriate, will need to:



• Work with the Police and other security agencies to develop and implement a
local strategy to guide proposals for appropriate security measures at public
buildings and spaces;
• Work with local Police Counter-Terrorism Security Advisors, Crime Prevention
Design Advisors, Designing Out Crime Officers and Architectural Liaison
Officers where appropriate to ensure that they inform them of planning
applications concerning the development of crowded places, transport hubs
and critical infrastructure;
• Involve Police and appropriate design advisers in the preparation of site
allocations in emerging plans.



Chief Planning Officer letter, July 2017



22. On the 12th July 2017, a letter from the Chief Planning Officer was published by the
Department of Communities and Local Government. This reminded local planning
authorities of the important role the planning system plays in ensuring appropriate
measures are in place in relation to counter-terrorist and crime prevention security. It
encourages, where appropriate, pre-application discussions between planning
officers and security advisors, such as Counter Terrorism Security Advisors and
Police Crime Prevention Design Advisors, to ensure that authorities and applicants
share an understanding right at the beginning of the design process, of the level of
risk and the sort of measures available to mitigate the risk in a proportionate and well-
designed manner. In addition to the need for reference to be made to the requirements
in the NPPF and the PPG, the letter also states that reference should be made to the
guidance ‘protecting crowded places: design and technical issues’.



‘Protecting crowded places: design and technical issues’, April 2014

23. Protecting crowded places: design and technical issues’, updated in April 2014, is
aimed at everyone involved in the planning, design and development of the built
environment to give advice about counter-terrorism protective security design.



Black Country Core Strategy (BCCS), 2011



24. The BCCS recognises in the supporting justification text for Policy DEL1 Infrastructure
Provision, that in addition to overall targets and standards set in the Core Strategy,
there would also be locally specified requirements, such as crime prevention measures.

Conclusions



71. The CCWMP has a statutory duty to secure the maintenance of an efficient and
effective Police force for its area and the Council has a statutory requirement to
consider crime, disorder, and community safety in the exercise of its planning functions.



72. It is requested that in accord with national planning policy, the theme of community
safety and crime prevention is given prominence in the Black Country Plan to promote
improvements in community safety, reducing crime, fear of crime and anti-social
behaviour, which are vital objectives in the context of creating sustainable communities.



73. The CCWMP formally requests that relevant officers are invited to be involved in
formulating appropriately worded policies. Joint working in partnership with the West
Midlands Police will help to ensure a sustainable plan which meets the requirements of
the NPPF. The CCWMP welcomes work to date securing a Service Level Agreement
setting out the protocol for joint working on responding to planning applications and
pre-application advice requests as appropriate.



74. The local police Senior Leadership Team and Neighbourhood Policing Unit are likely
to have detailed knowledge about site specific issues in respect of crime and safety
and any needs arising from the proposed additional residential and employment land
allocations in specific areas. Additionally, the centrally-based Design Out Crime Team
(DOCT) have extensive knowledge of security measures and ‘Designing Out Crime’.
The CCWMP requests that the Senior Leadership Team, Local Policing Unit and
Design Out Crime Officers are engaged in policy implementation and delivery once the
Black Country Core Strategy Review is adopted.

Comment

Representation ID: 22628

Received: 11/10/2021

Respondent: National Highways

CONSULTATION ON THE DRAFT SUBMISSION VERSION OF THE BLACK
COUNTRY PLAN


National Highways welcomes the opportunity to provide comments on the draft
submission version of the Black Country Plan (July 2021) which covers the period up to
2039. This replaces the Black Country Core Strategy (2011) and replaces significant
elements of ‘Tier 2’ plans in the form of Area Action Plans and Site Allocations for Dudley,
Sandwell, Walsall, and Wolverhampton.
National Highways has been appointed by the Secretary of State for Transport as
strategic highway company under the provisions of the Infrastructure Act 2015 and is the
highway authority, traffic authority and street authority for the Strategic Road Network
(SRN). It is our role to maintain the safe and efficient operation of the SRN whilst acting
as a delivery partner to national economic growth.
Within the Black Country, the SRN comprises the M5 and M6 motorways, and the A5
trunk road.
In responding to Local Plan consultations, we have regard to DfT Circular 02/2013 -
Strategic Road Network and the delivery of sustainable development (‘the Circular’) which
sets out how interactions with the Strategic Road Network should be considered in the
making of local plans. Paragraph 16 of the Circular sets out that:
“Through the production of Local Plans, development should be promoted at locations
that are or can be made sustainable, that allow for uptake of sustainable transport modes
and support wider social and health objectives, and which support existing business
sectors as well as enabling new growth.”
In addition to the DfT Circular 02/2013, the response set out below is also in accordance
with the National Planning Policy Framework (NPPF) and other relevant policies.

Based on our initial review of the draft submission version of the Plan, reports and other
supporting documents, we have identified the items below where we require further
information or clarification to help in completing our review of the draft plan:

Object

Representation ID: 23209

Received: 11/10/2021

Respondent: Member of Parliament

Number of people: 2381

As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.

Support

Representation ID: 23212

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Objectives and Strategic Priorities

HD welcome the inclusion of ‘Housing that meets all our needs’ as a Strategic Priority and consider themselves well placed to assist with helping meet these needs. We return to this point below.

Object

Representation ID: 23223

Received: 11/10/2021

Respondent: Member of Parliament

As one of the thirteen Members of Parliament in the Black Country area I welcome the opportunity to comment on the proposed new Draft Plan that includes my Aldridge-­Brownhills constituency.
In recognizing that there is a requirement on the part of all local planning authorities to undertake a Local Plan that identifies where development will take place over a 20-year framework, the Plan in its current form is significantly flawed particularly in the Borough of Walsall and in large parts of the eastern flank of the Borough which includes the entire Aldridge-Brownhills constituency.
Throughout this submission I wish to outline how in repeated instances the land proposed in the Plan, which for a large part is for development on designated Green Belt, fundamentally goes against public opinion and planning guidance. Whilst accepting that there are to be further iterations of this document it is important that these concerns are expressed at this stage of the process, and addressed.
I note that under the heading 'What does this mean for Walsall?" the following figures are quoted: ­
• Additional Land needed to build additional homes: 13,344
To be provided as follows:­
• Urban areas and Brownfield sites: 7,928
• Green Belt sites: 5,418
However, throughout the proposed Plan there is no information available to explain the rationale for how these figures have been derived. Furthermore, if these figures are extrapolated over a 20 year period they are likely to be over exaggerated, and certainly not reflective of need.
The Office for National Statistics states:­ "The UK population growth rate from mid-2018 to mid-2019 was at 0.5% slower than any year since mid-2004".
In addition it states:­ "migration has continued to be the main driver of UK population growth since the 1990s".
On the basis that there is falling migration and a falling UK population growth rate, the forecast number of homes used for the purpose of the Black Country Plan is over exaggerated and must be revised downwards before moving forward. Furthermore it takes no account of the impact on business or housing needs as we emerge from the Coronavirus pandemic.
Yet for the purpose of the Black Country Plan there is an inbuilt assumption that these figures are accurate, thus locking communities across my Aldridge-Brownhills constituency into a plan that is fundamentally unfair and which at its heart devastates several of our most valuable Green Belt sites and our natural environment, at a time when the focus should be on building back better, greener and more sustainably. A key way to achieve this is to develop on brownfield sites first, of which we have many across the West Midlands, and focus as a priority on our town and urban/district centres.
Constituents from across Aldridge-Brownhills would be forgiven for not sharing the sentiments set out in the Black Country Plan where in Paragraph 4.6 it states:­
"The BCP adopts a brownfield-first approach to maximise delivery of development within the urban area".
As a community we are on the urban fringe of the West Midlands 'Metro' conurbation and I am still seeking to understand in the Borough of Walsall the extent to which that policy has been put into practice.
Furthermore in the same paragraph the authors of the Plan undermine their opening statement by declaring:­ "however, poor ground conditions are a legacy of the Black Country's mining and industrial past are a significant constraint, in both physical and financial terms". This assertion must be challenged.
In recent years, we have seen the steps taken and significant investment to successfully assist with the remediation of brownfield sites for housing. The United Kingdom is on the verge of playing global host to the UN Climate Change Conference (COP 26), yet it is unclear what full and proper assessment has been undertaken of all available brownfield sites in my constituency ahead of proposing large swathes of development on existing Green Belt sites.
It is extremely disappointing that the Black Country Plan fails to live up to its brownfield first policy aspiration, nor even recognises the value and multiple benefits that such a policy and protections would create.
By failing to live up to that policy the Green Belt will undoubtedly be sacrificed first, our communities and environment damaged and the opportunity to regenerate urban and brownfield sites lost for a generation, if not forever.
Turning again to the figures on which this Plan is based and even on the basis of the flawed starting point of 13,344 units required over 20 years, this equates to 667 units per year.
Adopting an urban and brownfield sites first policy would provide 12 years of homes without having to touch any of the Green Belt sites.
If the trajectory of population growth continues to fall and migration flows reduce, the preservation of our Green Belt would endure for longer, if not indefinitely, whilst housing need can be met on brownfield sites, and our towns and district centres are regenerated and reinvigorated to be able to meet the challenge of the post Covid-19 era and provide the needed homes.
Without such a commitment to uphold the development of brownfield sites first, developers will simply continue to choose Green Belt sites over brownfield sites seeing them as the easier and cheaper model for development.
The stated aims of the Green Belt and the protections that it is given are well documented. There should be no de-designation of existing Green Belt.
As identified in the National Planning Policy Framework, the Green Belt serves 5 key purposes. Key amongst those objectives is to check the unrestricted sprawl of large built up areas.
On all of the key sites identified on Green Belt land in my Aldridge-Brownhills constituency, these principles are being set to one side to meet questionable targets and quotas that for the reasons I have identified above have not been justified in the Plan.
The Plan states, "the density of housing development in the existing urban areas will be increased to ensure that the land is used efficiently". There is widespread support to ensure the better utilisation of existing development land especially were it allows an increase in density and infilling for new homes, however there are no details or examples contained within the Plan as to how this can be fully achieved.
Whilst such an approach is to be welcomed, to fully understand whether this approach has been adopted by the Plan more information is required, particularly to understand if these are reflected in the proposed numbers.
Strategic Priorities 3 and 4 contained within the Plan carry widespread public support: ­
"to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents".
"to improve and diversify the Black Country housing offer".
However, the proposed Plan identifies a large number of sites within the Aldridge-Brownhills constituency that will certainly not meet the identified strategic priorities as set out. The average spend by a first time buyer across England stands at £205,246. Average house prices in Aldridge, Pelsall and Streetly all stand above the average first time buyer rate and the West Midlands average.
Indeed, in the case of two of the proposed sites (Aldridge Road/Queslett Road East and Stonnall Road) average prices based on the West Midlands average are between 51% and 110% higher.
Several of the current proposed sites will not manage to meet the stated objectives in these strategic priorities, they could in fact further fuel levels of unaffordability as this proposed plan will not provide the necessary housing mix.
In seeking to achieve a balanced plan, I applaud the aim of seeking to enhance the vitality of our town centres. Key Government support projects prior to and since the Covid-19 pandemic seek to recognise the changing face of our High Streets and Village Centres.
Yet the Black Country Plan fails to take full advantage of any changing High Street within my own constituency. All of the development is predominately focussed on existing Green Belt sites and on the outskirts of Village Centres well away from our High Streets.
Transport Infrastructure and the enhancement of sustainable and active travel are to be applauded and should be central to any development plan, but it is unclear from within the proposed plan how this will be underpinned by the current document.
A number of the proposed sites across Aldridge-Brown hills currently suffer from severe daily congestion, including Aldridge Road/Queslett Road East, Wolverhampton Road, Pelsall Road/Clayhanger junction and Stonnall Road.
Large parts of the road network cannot cope with the existing number of properties/vehicles, in the case of the proposed Aldridge Road/Queslett Road site the imposition of 960 properties most of which would turn right towards Birmingham would lead to even further increased gridlock in both directions given at the same time more than 1,900 school children are currently seeking to access the existing road network.
Whilst constituents would welcome steps towards more sustainable levels of transportation, it is highly questionable as to whether we can justify attempting to take these vital necessary steps when there is a lack of detailed transport modelling to accompany the proposed plan.
Further, Paragraph 4.9 supports the fact that this has not happened and only remains 'on-going'. Improved sustainable travel will not account for the loss of the natural environment with large swathes of Green Belt being lost for a future generation.
No proper thinking has underpinned education needs and the impact that the proposed sites in Aldridge-Brownhills would place on the already pressured school network. With large numbers of schools across the constituency already at capacity and the pressure of the additional number of homes being proposed, I am concerned as the Member of Parliament that schools would not be able to accommodate such an influx of new development.
Equally, across my Aldridge-Brownhills constituency, we have witnessed in recent years an increase in the amount of flooding that has taken place in areas where the Black Country Plan has proposed a large number of these new properties. Areas such as Wolverhampton Road and Aldridge Road/Queslett Road East sites have had repeated instances of flooding in recent years including the flooding of homes.
To remove even more natural soakaway in several of these areas would have a detrimental effect on existing residents. This should not be overlooked at the initial stages of site allocation/preference in this Plan as it should include work on the existing drains and sewers too.
The importance of Green Belt and Green Open Spaces came to the fore at the start of the Covid-19 pandemic, when people being allowed to go out for exercise for one hour per day supported personal health and wellbeing. Whilst none of us will wish to go back into such stringent lockdown arrangements ever again it did open our eyes to the importance of open spaces and the natural beauty of the environment which exists around us. Another point overlooked in the current Plan is that of the wider environment and the impact of this Plan on woodland, hedges, natural habitats and the loss of valuable far land currently used for food production.
Whilst acknowledging that the current consultation has worked within the framework of the statutory guidelines set down, I do not believe that it has worked within the spirit.
A more rigorous communication plan should have been in place to raise the spectre of the importance of this consultation particularly in areas which could potentially be most affected by any future plan to implement.
In my own constituency Councillors alongside volunteers have been left to play their civic role in seeking to encourage large-scale participation, but we all believe that this should have been backed up with greater central co-ordination.
There is widespread understanding amongst residents from my Aldridge-Brownhills constituency that we need to plan new homes for future generations, the only question we would ask is do we have to facilitate these whilst destroying some of our most precious Green Belt and Open Spaces?
The latest iteration of this Plan is unacceptable to me as the Member of Parliament for Aldridge-Brownhills and to large numbers of my constituents who have contributed to this consultation.
In responding to your consultation, I am insisting, on behalf of the constituency of Aldridge­ Brownhills, that the Black Country Plan lives up to its own aspiration to promote a development policy of Brownfield First.
As such I am expecting this plan Switches the Strategy back to Brownfield First and away from Green Belt, for the reasons identified by myself and the many contributors to this consultation.
At the start of this consultation process, I opened my own petition for this Plan to return to its core principles and some 2,611 have signed from across Aldridge-Brownhills to 'Switch the Strategy' back to Brownfield First. All of this information is appended to my submission.
Green Belt sites can only be developed once, and we owe it to all the future generations of this country in an era of environmental vigilance to protect designated Green Belt sites and adopt a policy of Brownfield First development. On behalf of my constituents from Aldridge­ Brownhills I urge the next iteration of this strategy to do exactly that.

Comment

Representation ID: 23304

Received: 18/09/2021

Respondent: Mr David Aston

Children need to kick a ball and run around with their friends, not sitting in the house with electronic toys.

Support

Representation ID: 43804

Received: 04/10/2021

Respondent: John Mason Associates Ltd

Agent: John Mason Associates Ltd

Land to Rear of 105 Skip Lane

1.1 The Black Country Plan (formerly known as the Black Country Core Strategy) is a plan prepared by the four Black Country authorities (Walsall, Dudley, Sandwell, and
Wolverhampton) to identify and allocate for development sufficient land for housing and employment needs for the next 15 years.

1.2 Government requires a review of all land use plans every five years. The current Core Strategy was adopted in 2011. It is currently projected that the Black Country Plan will be adopted during 2023 and will allocate sufficient land to meet housing needs for 15
years or until 2039.

1.3 During 2018, Government introduced a standard calculation for working out how many new homes are required. Using this method, the Black Country had a need for 3,761 new homes each year or 71,459 homes in total over the Black Country period from 2020 – 2039.

1.4 In our view even allowing for the number of houses that can be accommodated on brownfield land in Walsall and taking this number of the total number of houses
required there is still a gap which will require Walsall Council to allocate land in the Green Belt.

1.5 Subsequent to the above, this statement provides an assessment of the proposals and justifies how the proposed development accords with relevant planning considerations before concluding that it should be supported, and the site should be allocated for residential development.

Support

Representation ID: 44891

Received: 11/10/2021

Respondent: Gladman Developments Ltd.

Gladman welcomes the review of the Black Country Plan to cover the period to 2039 and the intention to meet housing needs and attract new businesses as an integral component of the Plan’s Spatial Vision, Strategic Objectives and Strategic Priorities. Strategic Priority 3: to provide a range and choice of accommodation, house types and tenures to meet the needs of current and future residents is of fundamental strategic importance and is central to the preparation of a sound Local Plan.

Comment

Representation ID: 44962

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

INTRODUCTION
This report has been prepared by Lichfields on behalf of Taylor Wimpey UK Limited LTaylor
Wimpeyl. It forms Taylor Wimpey's response to the Draft Black Country plan IBCPI
(Regulation 18) consultation and is submitted for consideration in the formulation of the Plan.
These representations are submitted in the context Of Taylor Wimpey's land interests on the
following sites:
1 Land at Mob Lane, Pelsall (LPA: Walsall)
2 Land at Chester Road, Streetly (LPA: Wal sall)
3 Land at Cle nt View Road, Stourbridge (LPA: Dudley/ South Staffordshire)
Taylor Wimpey is seeking the alloeation Of all the sites for residential development in the BCE
Plans showing the locations of these sites are attached at Appendices 1 to 3.
Land at Mob Lane, Pelsall has been identified as part of a larger Strategic Allocation in the Draft
BCP (Policy WSA.2 - Land at Vicarage Road and Coronation Road, High Heath and land at Mob
Lane, Pelsall).
The Chester Road and Clent View Road sites have not been Identified as draft allocations and
are currently identified as Green Belt. Taylor Wimpey in these æpresentations sets out the
reasons why these two sites should also be identified for residential development to meet the
BCA housing needs.
Taylor Wimpey is part of a wider consortium of house builders being represented by Turley.
Turley has been instructed by the consortium to take stock of the position relating to housing
need and land supply across the Greater Birmingham and Black Country Housing Market Area
IGBBCHMAI in order to quantify the true scale of unmet need to 2031, and beyond, mindful
that emerging local plans are seeking to deliver growth into the late 2030s or, in several cases,
beyond 2040. A copy of the Turley report' prepared on behalf of the consortium is attached at
Appendix 4.
The following documents also accompany these representations:
2
3
4
5
6
7
Bruton Knowles Viability Review — Appendix 5
Chester Road Streetly. Alternative Masterplan — Appendix 6
Green Belt Technical Report (supplied as a separate document)
Mob Lane, pelsall Delivery Statement (supplied as a separate document)
Mob Lane, pelsall Transport Note (supplied as a separate document)
Chester Road, Streetly Delivery Statement (supplied as a separate document)
Clent View Road, Stourbridge Delivery Statement (supplied as a separate document)
Structure
This report provides detailed representations in relation to the following matters relating to the
Draft BCP:
1 Policy CSPI - Developm ent Stratew
2 Policy CSP3 - Towns and Neighbourhood Areas and the Green Belt
3
4
5
6
7
8
9
10
12
13
14
15
16
17
18
19
20
21
22
23
24
Policy CSP4 - Achieving well-designed places
Policy GBI - The Black Country Green Belt
Policy DELI
Infrastructure Provision
policy DEL3
promotion Of Fibre to the premises and 5G Networks
policy
- Health and Wellbeing
policy HW2
Healthcare Infrastructure
policy HW3
Health Impact Assessments
policy CENI
The Black Country Centres
policy HOUI
- Delivering Sustainable Housing Growth
policy HOU2
- Housing Density, Type and Accessibility
policy HOU3
Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build
Housing
Policy HOU5
Education Facilities
Policy TRAN8 - Planning for Low Emission Vehicles
Policy ENVI - Nature Conservation
Policy ENV2 - Development Affecting Special Areas of Conservation (SACs)
Policy ENV3 - Nature Recovery Network and Biodiversity Net Gain
Policy ENV4 — Provision, retention and protection of twes, woodlands and hedgerows
Policy ENV9 Design Qual ity
Policy CC2 - Energy Infrastructure
Policy CC7 - Renewable and Low Carbon Enerv and BREFAM Standards
Sub Areas and Site Allocations — Dudley
Sub Areas and Site Allocations - Walsall
The National planning policy Framework (the Framework) was revised on 20th July 2021. As
the BCP and associated documents were approved for consultation before this date we note that
they do not take account of the revised Framework and this will be considered as part of the next
Stage Of plan preparation. Any references to the Framework in these representations relate to
the July 2021 Framework unless otherwise stated.