Draft Black Country Plan

Comment

Representation ID: 45881

Received: 11/10/2021

Respondent: Transport for West Midlands

Overall TfWM welcomes the land use options presented in this chapter and that predominantly the Strategic Centres and Core Regeneration Areas are the primary focus for sustained regeneration and infrastructure investment to support the delivery of growth. These locations are already served by an extensive public transport system and provide the most suitable locations for economic and housing growth from a transport perspective.

However, with the extent of growth planned, there will be limited capacity for travel on the existing networks and modes and while the transport chapter presents an array of schemes to assist with this growth, the traffic modelling datasets and evidence (setting out the travel demand across all modes) is still missing. This means it is unclear whether the potential mitigation measures which might be required to minimize and manage the travel demand increase will be enough to off-set the growth and support wider social, economic and inclusion objectives.

Comment

Representation ID: 45882

Received: 11/10/2021

Respondent: Transport for West Midlands

Overall TfWM welcomes the land use options presented in this chapter and that predominantly the Strategic Centres and Core Regeneration Areas are the primary focus for sustained regeneration and infrastructure investment to support the delivery of growth. These locations are already served by an extensive public transport system and provide the most suitable locations for economic and housing growth from a transport perspective.

However, with the extent of growth planned, there will be limited capacity for travel on the existing networks and modes and while the transport chapter presents an array of schemes to assist with this growth, the traffic modelling datasets and evidence (setting out the travel demand across all modes) is still missing. This means it is unclear whether the potential mitigation measures which might be required to minimize and manage the travel demand increase will be enough to off-set the growth and support wider social, economic and inclusion objectives.

Comment

Representation ID: 45883

Received: 11/10/2021

Respondent: Transport for West Midlands

The way streets and places are designed and ultimately managed (i.e traffic regulations or the physical designs of our streets) are vitally important to help manage the overall levels of traffic, dominance of vehicles and how comfortable people feel using sustainable and active travel modes. Unfortunately, certain groups do not always feel safe (including women, transgender groups and disabled groups as examples), and so measures need to be implemented to tackle any barriers which exist in new developments, including appropriate safety measures. This point should therefore be set out more strongly in this policy section.

Comment

Representation ID: 45884

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst we recognise the constraints of accommodating the majority of the Black Country’s housing needs within the existing urban area, from a transport perspective these locations are almost always more suited for new development – where good public transport serves high-volume corridors and the provision of consumer amenities are close to where they live and work. While the impact of new development will continue to have a significant (and often detrimental) impact on existing networks, as evidenced in numerous studies including the Walsall to Wolverhampton Corridor Study, it is vital the transport measures proposed, mitigate against any negative transport impacts – especially those which further reduce the viability or attractiveness of alternatives to private car usage.

Unfortunately, from the above corridor study findings together with PRISM outputs, the proposed infrastructure improvements for this corridor appeared to do very little to offset the increase in travel demand or affect positively, travel behaviours in the area. Therefore, an increase in car mode share and a decrease in bus, walking and cycling mode shares was predicted by the study, with any new development planned only exacerbating existing transport issues in the corridor.

With this in mind, it is only where no other possible sites are available should sustainable urban expansions of greenbelt land be explored and TfWM will continue to work alongside the Black Country authorities to fully understand the levels of sustainable transport provision, alongside the necessary mitigation measures required to support such proposed growth.

Comment

Representation ID: 45885

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst we recognise the constraints of accommodating the majority of the Black Country’s housing needs within the existing urban area, from a transport perspective these locations are almost always more suited for new development – where good public transport serves high-volume corridors and the provision of consumer amenities are close to where they live and work. While the impact of new development will continue to have a significant (and often detrimental) impact on existing networks, as evidenced in numerous studies including the Walsall to Wolverhampton Corridor Study, it is vital the transport measures proposed, mitigate against any negative transport impacts – especially those which further reduce the viability or attractiveness of alternatives to private car usage.

Unfortunately, from the above corridor study findings together with PRISM outputs, the proposed infrastructure improvements for this corridor appeared to do very little to offset the increase in travel demand or affect positively, travel behaviours in the area. Therefore, an increase in car mode share and a decrease in bus, walking and cycling mode shares was predicted by the study, with any new development planned only exacerbating existing transport issues in the corridor.

With this in mind, it is only where no other possible sites are available should sustainable urban expansions of greenbelt land be explored and TfWM will continue to work alongside the Black Country authorities to fully understand the levels of sustainable transport provision, alongside the necessary mitigation measures required to support such proposed growth.

Support

Representation ID: 45886

Received: 11/10/2021

Respondent: Transport for West Midlands

TfWM fully supports the use of planning obligations to generate contributions for local and sub-regional transport infrastructure. All the transport infrastructure identified in the statutory WM LTP (including our current delivery plan) should be clearly stated within this policy. Sustainable transport infrastructure should also be noted in paragraph 4.24 and fully prioritised across all new development.

Comment

Representation ID: 45887

Received: 11/10/2021

Respondent: Transport for West Midlands

There is strong evidence that the spatial proximity of amenities have greatly influenced and will continue to influence peoples patterns of travel demand. As land uses have become more dispersed and cars more affordable, greater switches from public transport to car usage have been witnessed, leaving many services out of easy reach of the 32% of the region’s population who don’t own a car. It is therefore vital that all new development provides appropriate access to opportunities for training, apprenticeships and local jobs, especially for those most vulnerable and those living in deprived deciles within the indices of multiple deprivation.

The WM LTP Green Paper has also outlined the benefits of closer links between transport and land use planning – in order to help create places in which people’s daily needs can be met within a short walk, cycle or by public transport.

Comment

Representation ID: 45888

Received: 11/10/2021

Respondent: Transport for West Midlands

While we support policy DEL3 to roll out digital connectivity across the Black Country, it fails to capture how enhancing digital services may help reduce the need to travel or mitigate the transport impacts of new development.

Under this policy, reference should also be made to the Key Route Network’s ‘Connecting Communities’ programme. Sited at the heart of the region’s digital connectivity movement, there is huge opportunity to build upon the existing digital infrastructure already in place across the Black Country. In turn helping reduce the need to travel, impacting positively on safety and reducing the overall demand on the transport network. And therefore, we welcome policy to this in the Black Country Plan.

Comment

Representation ID: 45889

Received: 11/10/2021

Respondent: Transport for West Midlands

Policies HW1, HW2 & HW3 Heath and Wellbeing, infrastructure and Assessments

Under these policies, we would welcome reference to TfWM’s Health and Transport Strategy and its supporting evidence, along with more emphasis on how improved sustainable transport links can deliver on improvements to people’s health outcomes. For example, through reducing health inequalities, cleaner air, increased active travel levels, safer roads, reduced noise pollution and improved levels of social cohesion. These issues are not currently picked up under this policy but are vital to health outcomes.

Comment

Representation ID: 45890

Received: 11/10/2021

Respondent: Transport for West Midlands

Policy HOU1 & 2 Delivering Sustainable Housing Growth

Alongside the focus for new homes to be built within Centres and Core Regeneration Areas, housing policies should consider the importance of building new homes along key transport corridors and transport hubs. And while these Core Regeneration Areas may well be along some key public transport corridors, this is not explicitly highlighted in the policies, but we feel this needs to be demonstrated throughout the plan.

To help meet housing requirements, the Black Country should also continue to examine increasing minimum housing density levels in its centres to 50 or more per hectare as promoted by the RTPI4 and the Urban Transport Group. A review of minimum densities of local plans and spatial frameworks in other UK City Regions could be of value, with areas including Greater Manchester and Liverpool presenting housing density levels as high as 75 dwellings per hectare for houses and 150+ dwellings per hectare for apartments. Increasing dwelling densities, in more built up urban areas will then help create more walkable mixed-use developments, with excellent sustainable mobility options while reducing the need to travel by car.