Draft Black Country Plan

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:

Comment

Representation ID: 22629

Received: 11/10/2021

Respondent: National Highways

Meeting the Housing Need:
The BLP commits to the delivery of 47,837 new homes over the course of the plan.
However, the Black Country Authorities have evidenced a significant shortfall through its
2019 Urban Capacity Review Update of up to 29,260 between 2019 and 2038. It is
anticipated that housing shortfall will be delivered by neighbouring authorities.
At present, based on our review National Highways cannot establish whether the level of
housing growth can be accommodated on the SRN as the transport evidence base or
strategic transport assessment which support the plan have been provided.
We therefore request the provision of the transport evidence base, strategic transport
assessment and any supporting modelling to be provided. This will enable us to undertake
a full and robust assessment of the proposals and understand the impact on the safe and
efficient operation of the SRN.

Comment

Representation ID: 22630

Received: 11/10/2021

Respondent: National Highways

Meeting the Employment Need
The plan brings forward 281ha of employment site development at a number of locations
where their impacts upon the SRN are in proximity to junctions and corridors which are
currently at or exceeding capacity.
An additional aspiration of 71ha of employment land is committed to within the BLP, which
will be brought forward on other sites throughout the Black Country, mainly through the
redevelopment, intensification and enhancement of existing employment areas and
premises. Furthermore, a further 210ha of employment land is to be delivered by
neighbouring authorities. Similar to the shortfall in housing provision, the reallocation or
intensification of employment land and its distribution around the west midlands will be
crucial in the forecasting and assessment of transport impacts on the SRN.
However, based on our review National Highways are unable to conclude if this quantum
of employment land is acceptable. We therefore request the provision of the transport
evidence base, strategic transport assessment and any supporting modelling to be
provided. This will enable us to undertake a full and robust assessment of the proposals
and understand the impact on the safe and efficient operation of the SRN.

Comment

Representation ID: 22631

Received: 11/10/2021

Respondent: National Highways

Transport
It should be noted that we had anticipated that a new transport evidence base would be
submitted in support of the plan. By providing a transport evidence base, we as the
Strategic Highway Authority have a clear and defined reference for working alongside
Local Highway Authorities to plan for and mitigate against the impacts of forthcoming
future development, enabling infrastructure for growth.

A number of the documents that form the evidence submission in support of the plan are
considered dated, or in the case of the Black Country Plan Transport Modelling Study,
are unavailable for review. Therefore, a refresh of the evidence base should be
considered.
We welcome and fully support the plans statements on the need for and integrated and
sustainable transport network that seeks to encourage modal shift to public transport and
active travel.
However, we are uncertain about section of Policy TRAN 1 and what it contains as it is
considered out of date, or referencing schemes which are not committed.
M6 Junction 10
We are working collaboratively with Walsall Council to deliver the junction improvement
scheme at M6 Junction 10. This scheme aims to resolve the significant congestion and
traffic delay experienced at this location. It is anticipated that the scheme will be
completed by 2022.
We therefore conclude that it is not necessary to include M6 Junction 10 in Policy TRAN
1 and it should be removed.
M5 Smart Motorways
There are no plans or commitments for the implementation of Smart Motorways on the
M5 Corridor within the Black Country. In addition, it is unclear the rationale on which this
requirement has been based, as it has not supported with ourselves. We therefore
recommend that this scheme needs to be removed from the Local Plan and Policy TRAN
1.
M54 – M6/M6 Toll Link
The Development Consent Order (DCO) examination for the M54 – M6 Link Road has
now closed and the Planning Inspectorate on behalf of the Secretary of State has written
its recommendation report which has been submitted to the Government. The Secretary
for State for Transport now has three months to make a decision.
Therefore, we consider the scheme can remain in the Local Plan but the reference needs
to change to remove reference to the link to the M6 Toll. Therefore, the scheme should
be renamed as the M54 – M6 Link Road.

Comment

Representation ID: 22632

Received: 11/10/2021

Respondent: National Highways

Infrastructure Delivery
It is noted within the draft BLP it states that parts of the Black Country’s existing highway
infrastructure, and the motorway network, suffer from congestion, and that detailed
transport modelling work is ongoing, and this evidence will be available to inform the
documents publication.
National Highways disagrees with this approach as the transport evidence base and
transport modelling work should have been provided alongside this document as part of
the consultation. This would enable a robust assessment of the proposals to be identified
to ensure that the proposed levels of growth can be accommodated on the SRN and LRN.
As well as identifying what the transport infrastructure needs, and requirements are to
enable the proposed levels of growth to be sustainably accommodated and delivered.

At present we conclude that without the transport evidence base to support infrastructure
requirements and their delivery that the Local Plan in its current form is unsound.

Comment

Representation ID: 22633

Received: 11/10/2021

Respondent: National Highways

Environmental Transformation and Climate Change
It is noted that the draft submitted version of the local plan and identified allocations will
increase the number of residents in proximity of the SRN. It is likely that these locations
will be impacted by noise pollution from the SRN and raise the potential for exceedances
of air quality standards for which extraordinary measures in the form of permenant speed
restrictions have already been put in place on the M5 and M6.
Several policies, and the Black Country SPD set out requirements for developments to
reduce the impact on, or improve, local air quality but this does not directly relate to the
SRN and what mitigation may be required. We will continue to work proactively with
yourselves on these matters but would recommend a specific policy which identifies how
air quality impacts and noise pollution would be monitored and managed and what
interventions may be required.

Comment

Representation ID: 22634

Received: 11/10/2021

Respondent: National Highways

Health and Wellbeing
We support the HW1 policy which outlines the requirement for new development to
ensure access by inclusive, active, and environmentally sustainable form of travel and
through promoting road safety and managing the negative effects of road traffic, and look
forward to working with the authorities to facilitate such travel where interface with the
SRN occurs.
National Highways is committed to continue to work with the Black Country authorities in
a collaborative and constructive manner to support the progression of the Black Country
Plan. As part of this approach we will work with you to develop a greater understanding
of the impact of development allocated within the draft plan on the SRN.
We trust that the above is useful in the progression of the Black Country Plan and
welcome continued discussions with the Council to this end.