Draft Black Country Plan

Object

Representation ID: 17145

Received: 11/10/2021

Respondent: Worcestershire County Council

Minerals
We do, however, consider that the terminology of also supporting mineral extraction, separately from mineral safeguarding operations, within the Mineral Safeguarding Areas is somewhat confusing and does not match the terminology used in the national Planning Practice Guidance of planning for mineral extraction by designating "specific sites", "preferred areas" and "areas of search”.
Worcestershire County Council welcomes future discussions under the Duty to Cooperate on minerals matters.

Support

Representation ID: 17146

Received: 11/10/2021

Respondent: Worcestershire County Council

We welcome the inclusion of policies for the supply of minerals, particularly Policy MIN1 which seeks to ensure the Black Country supplies at least 25% of the seven-year sand and gravel landbank for the West Midlands Metropolitan Area over the plan period.
We welcome the inclusion of a Preferred Area for the working of sand and gravel resources to meet this identified demand.

Support

Representation ID: 17147

Received: 11/10/2021

Respondent: Worcestershire County Council

Waste
We welcome the inclusion of policies relating to ensuring sufficient waste management capacity, particularly policy W1, which includes in part (c) support for proposals where they ensure that “sufficient capacity is located within the Black Country to accommodate the waste capacity requirements during the plan period and reducing the reliance on other authority areas” (emphasis added).
Worcestershire County Council welcomes the recognition that 2% of waste imported into the Black Country is from Worcestershire and welcomes further Duty to Cooperate discussions related to cross-boundary movements of waste.

Comment

Representation ID: 17148

Received: 11/10/2021

Respondent: Worcestershire County Council

Worcestershire County Council and Worcestershire Children First have noted the proposed allocations within the Draft Black Country Plan, with particular reference to cross-border educational impact.
Planned housing development sites have been identified within close proximity to the border between the Black Country and Worcestershire. It is envisaged that a small proportion of the Black Country’s pupil yield will commute to schools within Worcestershire, increasing the number of pupils at schools along the border, namely at Hagley and Romsley.
We shall continue to monitor the impact of housing growth on Worcestershire schools in and around the local area and will respond appropriately to ensure a sufficiency of school places, in line with current published policies.
We will continue to work with schools serving the local area to protect and enhance school assets and playing fields, in line with Government policies on the delivery of statutory education provision.

Comment

Representation ID: 17149

Received: 11/10/2021

Respondent: Worcestershire County Council

WCC is the Highway Authority for Worcestershire and is responsible for operating and maintaining the county’s local road network, both in respect of current activities and needs as well as its long-term operation and integrity. It is on the basis of these responsibilities that the comments that follow are made.
Our network adjoins the Draft Black Country Plan area at the A456, to the immediate south of Halesowen, the M5 to the south of Quinton and the A449 located to the south of Stourton. We are keen to ensure that transport and land use planning policy is closely integrated, so that the Worcestershire transport network is able to facilitate the delivery of sustainable economic growth.
We are interested in the potential traffic impacts of any development site proposals and/or policies coming forward through the Local Plan process that may impact on Worcestershire’s highway and transport network, and need to ensure that these are fully assessed during the plan-making stage. It is imperative to identify any improvements needed to deliver aspirations at this early stage, as set out in Government policy.

In summary, as a minimum, in order for the transport evidence base to satisfy the requirements of the NPPF, it is necessary to establish:
• The transport impacts of the development allocations.
• The improvements necessary to ensure that the impacts are not severe.
• Any land required for the delivery of the necessary improvements
• The cost of the necessary improvements.
• Any other deliverability constraints.

Comment

Representation ID: 17151

Received: 11/10/2021

Respondent: Worcestershire County Council

Emerging Spatial Strategy
As set out in previous Regulation 18 consultation responses to the Draft Local Plan, we have concerns about the potential cumulative transport impacts of the growth set out in the Plan on the network within Worcestershire. It is clear that several proposed development areas could have an impact on the county’s transport network.
Previous responses have confirmed that the specific issues that should be considered are:
• Key transport routes in and around north Worcestershire including access to M5 junctions 3 and 4, and M42 junction 1.
• Some local roads are currently at capacity and transport modelling is necessary to understand the capacity of the local roads to accommodate further traffic generated from new development. In terms of the relationship between growth in the Black Country Plan area and Worcestershire’s highway network, these impacts will primarily be along WCC’s network into Bromsgrove.

Object

Representation ID: 17152

Received: 11/10/2021

Respondent: Worcestershire County Council

Land South of Holbeache, Land fronting Wolverhampton Road and the Holbeache Lane, Kingswinford (ref: SA-0017-DUD) - 330 dwellings.
Potential for traffic to be distributed onto A4036 and/or Hagley Road which would potentially impact WCC’s network into Bromsgrove.

Object

Representation ID: 17153

Received: 11/10/2021

Respondent: Worcestershire County Council

National Works, Hall Street, Dudley (ref: SA-0373-DUD) – 150 dwellings. Potential for traffic to be distributed onto WCC’s network leading into Bromsgrove.
• Land at Birmingham New Road (ref: H16.1a) - 472 dwellings (reserved matters), part of the site reallocated for employment use. Potential concern due to proximity to WCC’s network and distribution of traffic into Bromsgrove.

Object

Representation ID: 17154

Received: 11/10/2021

Respondent: Worcestershire County Council

• Whitehall Road, Tipton (ref: SA-0030-SAN) 5.3ha - employment. Potential for traffic to be distributed onto WCC’s network leading into Bromsgrove.
• Brandhall Golf Course (ref: SAH228) – 560 dwellings. Potential for traffic to be distributed onto WCC’s network leading into Bromsgrove.

Comment

Representation ID: 17155

Received: 11/10/2021

Respondent: Worcestershire County Council

Whilst we are less concerned about development proposals in Walsall and Wolverhampton, the Worcestershire County Council would welcome the opportunity to work with you to better understand both the cumulative impacts of the spatial strategy, and some site-specific impacts of the Draft Plan, on the county’s transport network.