Draft Black Country Plan

Object

Representation ID: 14477

Received: 07/10/2021

Respondent: Hagley Neighbourhood Plan Group c/o Hagley Parish Council

Agent: Hagley Parish Council

Land at Worcester Lane, Pedmore – sites DUH 206, 207 and 209
Transport Issues

This paper has been prepared by the Hagley Neighbourhood Plan Group on behalf of the Hagley Parish Council. It should read in conjunction with the Hagley Parish Council's separate response.

We strongly object to the Draft Black Country Plan (BCP) in relation to the proposed Worcester Lane developments on the basis that, whilst the Black Country, and specifically Dudley MBC, have every right to adopt an ambitious plan, they are bound by a duty to co-operate with adjoining local councils to consider the impact of their proposals and to agree mitigations where necessary. The need to co-operate is clearly accepted within the Transport Section of the Draft Plan. We do not believe that this process of co-operation has even started yet. Nor has any evidence been presented as to the traffic impacts of this site nor has any mitigation been proposed. We believe that this process should commence immediately and if, as we suspect, the evidence suggests a material negative impact on Hagley that should be sufficient for this particular site to be dropped from the plan.

Specifically, Hagley suffers from a major congestion issue on the A456, A450 and A491 roads that run through Hagley. The A456 and A491 have been proposed for inclusion in the government’s proposed Major Road Network which is aimed to complement the Strategic Road Network as roads which carry a high proportion of traffic with a national economic significance. These roads through Hagley are already running close to (or at certain junctions above) capacity with consequent problems of congestion, air quality, and safety. In particular, the A456/A450 junction at Cross Keys, the A456/B4187/Western Road/Summervale Road junction, and the A456/A491 junctions at the Cala Development and at the Cattle Market are severely congested in both the morning and evening peaks. We believe that the proposed Worcester Lane development will have a material impact on all of these junctions; whilst the development is relatively small it can be expected to generate up to 50 additional vehicle movements in the morning and evening peaks and even this small number will be enough to cause considerable additional congestion at junctions which are already at capacity.
ote that the A456 carried 31,852 vehicles in a day in 2011 (Annual Average Daily Traffic – AADT, taken from TDHA) and this can only be expected to have increased since then. Unfortunately, there is no recent reliable vehicle count on this road due to the pandemic.

The location of the proposed development on the SE edge of the Black Country conurbation is likely to attract residents who wish to commute to Birmingham, or further afield via the Motorway network. This would mean that they would travel up Redlake Road to join the A491 and hence the A456 or, because of the considerable peak time congestion at this junction, they would travel into Hagley along the B4187 to its junction with Park Road which would, in turn give access to the A456 or A491.Unfortunately this junction (B4187/Redlake Road) is already heavily congested in the peaks and Redlake Road is a major concern with parking for school drop offs/pick ups tending to partially block the road.

The only alternative for someone wishing to access the A456 or A491 for Birmingham or the Motorway network would be along Bromwich Lane which is very narrow and totally unsuitable for more than very limited use.

There is increasing evidence of re-routing and “rat runs” being used by frustrated drivers, often on unsuitable roads around Hagley. We fear that Bromwich Lane, which is already a favourite of taxi drivers, would be used in this way.

Unfortunately, this is just one of the proposed developments in the Hagley area that will generate more traffic through Hagley. The Wyre Forest Local Plan proposes developments at Lea Castle and Kidderminster East which will also create more traffic attempting to use junctions that are already at their capacity. In various documents WFDC have recognised the potential congestion problem in Hagley, and rightly raised the query as to whether further new developments in surrounding Authorities, particularly the Black Country Boroughs, could make these problems even worse. However, their only suggested solution is for a review at some point in the future, involving all of the main authorities in the area, to decide what actions are required. We strongly believe that just such a multi authority review is required now.
In the Transport Section of the Draft Black Country Plan (Para 9.34) there is a commitment that “all developments will be assessed both in terms of their impact on the transport network and the opportunities that could be available to ensure that the site is accessible by sustainable modes of transport”. The Plan also suggests that this would take the form of a full Transport Assessment or a less detailed Transport Statement for smaller sites. However it goes on to say that the decision as to which process will be used will be based on individual authorities guidance with a Transport Assessment “ sometimes being required instead of a Transport Assessment based on reasons other than spatial thresholds – “road safety concerns, existing congestion problems, air quality problems”. We would strongly suggest that all of the above apply to the impact on Hagley of this development and that the multi authority review suggested above is urgently required, based a full Transport Assessment.
Hagley would wish to recognise the assistance of WCC in making some recent small scale changes to the A456 junctions in Hagley (A456/A450 junction at the Cross Keys, the A456/A491 junction at the Cattle Market and the A456/B4187/Western Road junction). We expect these changes to make some small difference to the congestion issue but, unfortunately it will not be sufficient to resolve any of the problems.
Unless there is further action to resolve the congestion problems that already exist, and which will be exacerbated by the BCP and the WFLP, the already strongly negative comments that we are receiving from Hagley residents will continue. As part of the development of our Neighbourhood Plan we have consulted widely with our residents through, initially, consultation meetings and, more recently, through a “Hagley Census” which asked a series of questions about Housing, Transport and Environmental issues. These have indicated that:
• There is a major deterrent to walking or cycling in the village due to the volume of traffic and its speed.
• Elderly people report increasing social isolation (before the pandemic) as they are unwilling to leave their homes, other than in their cars.
• Residents are unwilling to let their children walk to schools in Hagley, or even to accompany them, due to the heavy traffic at peak times
We appreciate that DMBC is not responsible for the resolution of these problems but we do expect that they should recognise them and not take development action that will worsen them unless there are agreed mitigations in place that will, at the very least, not make the existing situation worse.

Object

Representation ID: 14483

Received: 07/10/2021

Respondent: Hagley Neighbourhood Plan Group c/o Hagley Parish Council

Agent: Hagley Parish Council

Land at Worcester Lane, Pedmore – sites DUH 206, 207 and 209
Transport Issues

This paper has been prepared by the Hagley Neighbourhood Plan Group on behalf of the Hagley Parish Council. It should read in conjunction with the Hagley Parish Council's separate response.

We strongly object to the Draft Black Country Plan (BCP) in relation to the proposed Worcester Lane developments on the basis that, whilst the Black Country, and specifically Dudley MBC, have every right to adopt an ambitious plan, they are bound by a duty to co-operate with adjoining local councils to consider the impact of their proposals and to agree mitigations where necessary. The need to co-operate is clearly accepted within the Transport Section of the Draft Plan. We do not believe that this process of co-operation has even started yet. Nor has any evidence been presented as to the traffic impacts of this site nor has any mitigation been proposed. We believe that this process should commence immediately and if, as we suspect, the evidence suggests a material negative impact on Hagley that should be sufficient for this particular site to be dropped from the plan.

Specifically, Hagley suffers from a major congestion issue on the A456, A450 and A491 roads that run through Hagley. The A456 and A491 have been proposed for inclusion in the government’s proposed Major Road Network which is aimed to complement the Strategic Road Network as roads which carry a high proportion of traffic with a national economic significance. These roads through Hagley are already running close to (or at certain junctions above) capacity with consequent problems of congestion, air quality, and safety. In particular, the A456/A450 junction at Cross Keys, the A456/B4187/Western Road/Summervale Road junction, and the A456/A491 junctions at the Cala Development and at the Cattle Market are severely congested in both the morning and evening peaks. We believe that the proposed Worcester Lane development will have a material impact on all of these junctions; whilst the development is relatively small it can be expected to generate up to 50 additional vehicle movements in the morning and evening peaks and even this small number will be enough to cause considerable additional congestion at junctions which are already at capacity.
Note that the A456 carried 31,852 vehicles in a day in 2011 (Annual Average Daily Traffic – AADT, taken from TDHA) and this can only be expected to have increased since then. Unfortunately, there is no recent reliable vehicle count on this road due to the pandemic.

The location of the proposed development on the SE edge of the Black Country conurbation is likely to attract residents who wish to commute to Birmingham, or further afield via the Motorway network. This would mean that they would travel up Redlake Road to join the A491 and hence the A456 or, because of the considerable peak time congestion at this junction, they would travel into Hagley along the B4187 to its junction with Park Road which would, in turn give access to the A456 or A491.Unfortunately this junction (B4187/Redlake Road) is already heavily congested in the peaks and Redlake Road is a major concern with parking for school drop offs/pick ups tending to partially block the road.

The only alternative for someone wishing to access the A456 or A491 for Birmingham or the Motorway network would be along Bromwich Lane which is very narrow and totally unsuitable for more than very limited use.

There is increasing evidence of re-routing and “rat runs” being used by frustrated drivers, often on unsuitable roads around Hagley. We fear that Bromwich Lane, which is already a favourite of taxi drivers, would be used in this way.

Unfortunately, this is just one of the proposed developments in the Hagley area that will generate more traffic through Hagley. The Wyre Forest Local Plan proposes developments at Lea Castle and Kidderminster East which will also create more traffic attempting to use junctions that are already at their capacity. In various documents WFDC have recognised the potential congestion problem in Hagley, and rightly raised the query as to whether further new developments in surrounding Authorities, particularly the Black Country Boroughs, could make these problems even worse. However, their only suggested solution is for a review at some point in the future, involving all of the main authorities in the area, to decide what actions are required. We strongly believe that just such a multi authority review is required now.
In the Transport Section of the Draft Black Country Plan (Para 9.34) there is a commitment that “all developments will be assessed both in terms of their impact on the transport network and the opportunities that could be available to ensure that the site is accessible by sustainable modes of transport”. The Plan also suggests that this would take the form of a full Transport Assessment or a less detailed Transport Statement for smaller sites. However it goes on to say that the decision as to which process will be used will be based on individual authorities guidance with a Transport Assessment “ sometimes being required instead of a Transport Assessment based on reasons other than spatial thresholds – “road safety concerns, existing congestion problems, air quality problems”. We would strongly suggest that all of the above apply to the impact on Hagley of this development and that the multi authority review suggested above is urgently required, based a full Transport Assessment.
Hagley would wish to recognise the assistance of WCC in making some recent small scale changes to the A456 junctions in Hagley (A456/A450 junction at the Cross Keys, the A456/A491 junction at the Cattle Market and the A456/B4187/Western Road junction). We expect these changes to make some small difference to the congestion issue but, unfortunately it will not be sufficient to resolve any of the problems.
Unless there is further action to resolve the congestion problems that already exist, and which will be exacerbated by the BCP and the WFLP, the already strongly negative comments that we are receiving from Hagley residents will continue. As part of the development of our Neighbourhood Plan we have consulted widely with our residents through, initially, consultation meetings and, more recently, through a “Hagley Census” which asked a series of questions about Housing, Transport and Environmental issues. These have indicated that:
• There is a major deterrent to walking or cycling in the village due to the volume of traffic and its speed.
• Elderly people report increasing social isolation (before the pandemic) as they are unwilling to leave their homes, other than in their cars.
• Residents are unwilling to let their children walk to schools in Hagley, or even to accompany them, due to the heavy traffic at peak times
We appreciate that DMBC is not responsible for the resolution of these problems but we do expect that they should recognise them and not take development action that will worsen them unless there are agreed mitigations in place that will, at the very least, not make the existing situation worse.