Draft Black Country Plan

Comment

Representation ID: 45891

Received: 11/10/2021

Respondent: Transport for West Midlands

This chapter provides very limited narrative on the importance of good transport accessibility to employment opportunities. Therefore, there is room to strengthen this chapter.

Comment

Representation ID: 45892

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst this policy aims to enhance accessibility to new development by a choice of transport options, we feel this needs to be expanded upon, especially because the distribution of employment opportunities often place the greatest demands on transport. The policy should more strongly address improving access to employment, especially by sustainable options. It should also set out how investment in transport across the Black Country can support the economic recovery from COVID-19, both in terms of direct employment to deliver on our infrastructure and services and through improved accessibility to employment opportunities.

Fully understanding exactly how investment in infrastructure then links to job creation and leveraging in jobs for local people across the Black Country is vitally important across the wider WMCA, and this is something Officers can assist with through making links with relevant colleges and providers.

It would further be beneficial for this section to set out how employment land proposals have taken into account the impacts of COVID-19 – especially concerning requirements for office space. Under policy DEL3: Promotion of Fibre to the premises and 5G networks.

Comment

Representation ID: 45893

Received: 11/10/2021

Respondent: Transport for West Midlands

When looking at trips at peak times, only 15% of all travel is to or from the key strategic centres of the Black Country, with 85% of people travelling elsewhere across the region. So while we want to maintain the role of such centres, especially for shopping and leisure trips we also see the relevance of smaller, neighbourhood centres and how improvements to these, and the development of ‘15 minute neighbourhoods,’ may help encourage more active travel and more localised access to key services. Tier 2 and 3 centres especially may lend themselves well to being ‘15 minute neighbourhoods’, especially where new development is taking place and this should be explored as a potential policy in the Black Country Plan.

Around 80% of travel to key centres is also for retail and leisure purposes, and we feel the economic benefits of footfall generated by public transport and active travel modes is often underestimated in such centres and needs to be more strongly emphasised in the policies.

Comment

Representation ID: 45894

Received: 11/10/2021

Respondent: Transport for West Midlands

Alignment to the region’s emerging statutory West Midlands Local Transport Plan 5

The new emerging WM LTP explores potential new policy pathways for regional and local transport, and whilst further work is still required to shape and develop this document, the role of land use policy is critical in shaping and delivering more sustainable travel behaviours across all new development.

In line with the adoption of WM2041 and wider national policy, the need to decarbonise transport will further be a critical objective, along with delivering inclusive growth, together with the importance of the ‘Triple Access System’. All these issues are captured in TfWM’s work undertaken to date on the new WM LTP Green Paper, and so should clearly be evidenced in this transport chapter.

The new LTP will also seek to consider the transport challenges presented in the draft Black Country Plan, and we will continue working with the Black Country authorities to ensure both plans are fully aligned.

Alignment to Regional funding strategies and investment programmes

Like with the synergy with the WM LTP, it is important the Plan reflects the commitments being established in regional funding streams like CRSTS, Levelling Up Fund, BSIP, the WM Rail Strategy and our current Delivery Plan. All the initiatives total over £1.5bn+ of programme support, to help deliver on more intelligent use of road space including the re-allocation of road space to deliver more enhanced, sustainable transport options.

Greater understanding of Transport Evidence Base and Transport Modelling

Currently the Draft Local Plan is missing detailed assessments and evaluation data of transport scenarios relating to the new land use policies. Comments are therefore very limited at this stage, and as the modelling data becomes available, we will be in a better position to understand just how the proposed policies will meet the demand from a range of modes. It is strongly encouraged that this work is robustly completed and TfWM are available to provide technical support where required.

Comment

Representation ID: 45895

Received: 11/10/2021

Respondent: Transport for West Midlands

TfWM welcomes these key transport priority schemes, but these must be fully cross referenced with the CRSTS scheme allocations and BSIP schemes.

In terms of point 3 in policy TRAN1, we feel this needs to be reworded to state “Key transport corridors will be prioritised through the delivery of infrastructure to support active travel (walking, cycling), public transport improvements (including HS2 Connectivity Package measures).

Concerning the rail schemes under point 4B, Wolverhampton – Walsall – Willenhall - Aldridge rail link are two separate schemes, and so should be presented as two in the policy.

West Midlands Rail Executive in particular, feel the plan needs expanding upon further, capturing several additional rail projects, and the policy text should therefore be amended to the following:
i. Wolverhampton – Walsall service and new Willenhall & Darlaston stations
ii. New Aldridge station and service to Walsall/Birmingham
iii. Midlands Rail Hub
iv. Wolverhampton – Shrewsbury Line Improvements

Additional policies should also be included in TRAN1 (rail section) and these are outlined below with further
details provided in appendix A:
v. Rail line re-openings of Sutton Park Line and Walsall – Lichfield
vi. Future rail network capacity upgrades vii.Train maintenance and stabling depots

And while there is some uncertainty about the rail proposals as referenced above, this doesn’t mean the schemes shouldn’t appear with in the Black Country Plan.

The proposed Walsall – Aldridge rail service along the Sutton Park line to Sutton Coldfield is achievable within the plan period, and with track improvements and platform lengthening at Wolverhampton and an additional platform at Walsall station being explored, and potentially delivered by around 2035, the safeguarding of this land will be essential.

Comment

Representation ID: 45896

Received: 11/10/2021

Respondent: Transport for West Midlands

Concerning the KRN, TfWM welcomes the inclusion of this policy but we would like to see further reference of the KRN Enhancement package which is part of CRSTS together with the Highway Investment Strategy and its Highway Investment Package Phase 2. This will be vital in supporting and monitoring the development of the KRN, in conjunction with the KRN Action Plans (produced in July 2021), which should also be included in the evidence base of the plan and referenced.

The new WM LTP reflects current Government strategies with a strong emphasis on the importance of the re-allocation of road space, with increased cycling and walking infrastructure and bus priority measures along the KRN. Recognition of this would be welcomed in Policy TRAN2 alongside the ‘Connecting Communities’ programme.

Finally, under paragraph 9.30 TfWM request that this be expanded upon to state: “Capital scheme improvements will be identified where appropriate, but it also is vital that this network is managed efficiently through the collaboration of all four authorities in their role as LHA together with neighbouring authorities where routes cross responsibility”.

Comment

Representation ID: 45897

Received: 11/10/2021

Respondent: Transport for West Midlands

Elements of this policy are welcomed, particularly in terms of transferring freight onto sustainable modes of transport like rail and waterways with some of the policy thinking echoing that of TfWM’s own Regional Freight Strategy, which will be updated in light of the new WM LTP. However, there are no policies on management measures in the form of restrictions on daytime road deliveries, consolidation initiatives or favourable policy in support driver facilities.

In particular, this policy section would benefit from addressing the role of consolidation centres for towns and opportunities for smaller logistics operations for last mile, such as local neighbourhood micro-consolidation facilities, improved routing software together with integrated online sales systems. The inefficiencies of the last mile problem have only been compounded by the continuous rise of ecommerce in retail, which has dramatically increased the number of parcels delivered, as well as raised customer expectations for fast delivery.

Policy TRAN4 could also address the use of cargo and eCargo bikes, ZEVs in freight and the use of micromobility and mobility hubs (including parcel lockers). In particular, supporting the shift toward ZEVs within the freight industry could be noted explicitly in this policy together with meeting the refueling needs, through appropriate freight charging stations as part of new development. Adopting cleaner technologies (to help meet air quality improvement goals laid down by the government) is also vitally important, especially as freight vehicles currently account for a disproportionately high percentage of harmful air pollutants.

There are also no policies which capture the importance of safety with regards construction vehicles or how these must not hinder sustainable and active travel infrastructure, especially for those more vulnerable road users. Potentially capturing the importance of Delivery and Servicing Plans and Constructions and Logistics Plans, as well as adherence to the Construction and Logistics Community Safety Scheme (CLOCS) could help minimise the impact both HGVs and LGVs will have on the surrounding highway, brought about through new development and construction. Also, in new developments themselves, the importance of ensuring good road safety measures is vital and needs capturing in this policy.

Freight parking requirements are also missing from this policy section, and TfWM would welcome exploration into potential sites for lorry holding areas as well as good off-street servicing facilities and provision of facilities for home deliveries within new developments, whilst not impacting on the wider public realm.

More explicit reference to the Major Road Network (MRN) should also be noted in the plan. This new category of economically important ‘A’ roads, and Large Local Majors (LLM) schemes (focusing on significant upgrades to local roads) will help unlock housing and economic growth and support the Strategic Road Network across the Black Country.

Policy TRAN4 could also be further expanded upon in terms of rail freight, through capturing further enhancements to the existing rail network which facilitate rail freight growth into and through the Black Country including network capacity and capability upgrades to allow more frequent, longer and heavier trains on key domestic and deep sea port routes.

Comment

Representation ID: 45898

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst we fully agree with the 7 principles outlined in this policy for walking and cycling, we feel this could be strengthened further, especially in light of the pandemic and the active travel fund measures being rolled out. Under point 1 especially, in terms of ‘maintaining a comprehensive cycle network’ this should include the words ‘safe and convenient network’.

The Metropolitan Cycle Network originally identified in LTP4: Movement for Growth is now known as the Starley Network. Stronger reference to the Starley Network should therefore be made together with the West Midlands Regional Walking and Cycling Strategy. Any cycling provision proposed within the plan should connect fully to all existing routes and these should be of high quality and designed to meet guidance set out by LTN 1/20 and the West Midlands Cycle Design Guidance under the Development and Places for People section.

New developments should not only have good walking and cycling links to public transport nodes and interchanges (as stated in point 4 of the policy) but have excellent links to all local amenities and services and be of mixed use and higher density (where possible) to help make the provision of sustainable transport economically viable and reduce the overall demand to travel, as stated under policy 4 & 6.

The reallocation of road space for cyclists should also be included under this policy, covering cycle lanes and pavement widening together with the importance of active travel behaviour change programmes such as TfWM’s community engagement programmes for active travel and that of its partners including School Streets and Low Traffic Neighbourhoods. Considering 20mph on all residential roads is also promoted in our West Midlands Cycle Design Guidance and TfWM’s Developer Guide, and we would welcome a 20mph policy for residential areas.

Finally, reference to the new West Midlands Cycle Hire scheme and the Interconnect West Midlands; the regions wayfinding system would be strongly welcomed.

Comment

Representation ID: 45899

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst there are many elements in this section TfWM strongly welcome, we feel this policy section could further be expanded upon, especially concerning the importance of behaviour change with prioritisation given to sustainable modes of travel, which will be vital in delivering a successful Black Country Plan.

Under point 1a Park and Ride, there is no mention of TfWM’s adopted Park and Ride Policy, nor is there no mention of expanding on Park and Ride ZEV charging and the use of parking charges at Park and Ride sites to encourage people to re-mode.

Under this point as well, considering future expansion of appropriate intercept Park and Ride sites for the Black Country (where users do not live near to inter-urban and local rail stations) maybe worth exploring further with TfWM Officers and included in policy, where appropriate. Yet also noting Park and Ride is not a demand management tool if it generates more car-based trips which could be walked and cycled.

Under point 1b, reference to the West Midlands UTC scheme is made, yet TfWM would also welcome acknowledgement of the Regional Transport Coordination Centre (RTCC).

In promoting and implementing Smarter Choice measures, there is no reference to micromobility (including escooters and ebikes), Demand Responsive Transport and the use of mobility as a service (MaaS) products and mobility credits. These shared transport services could play a key role in the early phasing stages of new development.

The growth of innovation and digital investment in transport is also playing a significant role in the region and we would welcome acknowledgment of this within all new development. As the West Midlands is benefiting from its Future Transport Zone, we believe all new development proposed should be designed to enable the installation of the most up-to-date digital connectivity and transport innovation measures.

The importance of good interchange facilities, across all modes for new development should also be referenced in this section.

Finally, the West Midlands is playing a leading role at the heart of the UK Connected and Autonomous Vehicle (CAV) ecosystem through developing and manufacturing its software and systems.

Comment

Representation ID: 45900

Received: 11/10/2021

Respondent: Transport for West Midlands

TfWM has responsibility for Park and Ride sites, certain electric vehicle charging infrastructure and some cycle parking provision. As part of wider policy and demand management measures, to restrain car usage and increase sustainable modes, we see car parking management measures being vital.

The current WM LTP4, Movement for Growth sets out a need for a metropolitan parking strategy to balance the role of car access to centres to support economic vitality, whilst promoting the use of sustainable travel. This is to ensure that private car volumes are not at such levels where the dominance of the car detracts from the quality of our centres.

Based on this, we welcome many of the points made under policy TRAN7, however the importance of good quality parking needs to be presented too. From TfWM’s LTP evidence review into parking, the ‘whole quality parking experience’ including how parking interconnects with other transport modes is seen as extremely important. And where ‘mobility hub’ style options are available with pop up shops, distribution lockers, ZEV charging opportunities and food outlets alongside standard car parks and sustainable transport options, these are welcomed, and have helped reduced the impact of parking in other towns and cities.

From our LTP evidence base research, we also know that only 20% of trips into centres are for commuting purposes with the remainder being for retail and leisure. There is also limited evidence to suggest that parking charges act as a deterrent to shopping trips, and its good quality pedestrian measures and investment in traffic reduction and public realm which increases retail footfall and makes the greatest impact on local high street economies, and we would be happy to share our evidence in this area, to help shape further the parking policies within the plan.

The NPPF also echoes this by stating “that local authorities should consider an area’s accessibility, type, mix and use of development, availability of public transport, local car ownership levels … when setting local parking standards”.

Based on this, paragraph 9.61 should be altered to read: “The management of car parking is fundamental to achieving the Vision for sustainable communities, environmental transformation and economic prosperity. It also has a key role in helping to reduce the overall level of private vehicle trips with obvious benefits for congestion, road safety, air quality and carbon emissions”.

Under policy TRAN7 1a, concerning parking measures between centres, we feel the decision to not include Brierley Hill (Merry Hill) within the parking policy for charging across strategic centres is a serious omission. It should be noted that the WMCA (under written by Dudley MBC and the other West Midlands constituent authorities) are investing many millions of pounds into improving public transport connectivity across the Black Country, including the Wednesbury to Brierley Hill Midland Metro Extension. To support this investment, substantial funding has been raised by loans which are linked to increased use of the Midland Metro (as part of its extension). This policy as drafted, has potential to create challenges with regards to the jointly targeted strategic outcomes of increased public transport usage as an alternative to single occupancy car usage.

Under more general comments now, there is no policy reference to parking facility / kerb side management requirements for freight, servicing and logistics, for ZEV charging points, for pick-up/drop off points for taxis, car club schemes, coaches and bus layover points, for powered two wheelers and cycle parking or parking for disabled people. Hence, policy TRAN7 could be expanded upon, to cover wider parking matters including:
• Promoting car free developments in those most accessible locations where excellent public transport is available.
• Introducing permit parking schemes for new developments.
• Ensuring adequate parking provision for disabled car drivers and passengers.
• Full consideration of ZEV charging infrastructure and parking, together with spaces for ZEV car clubs
– covering both off street and on street public parking provision.
• The need for all future stations/interchanges/mobility hubs to be designed with restrictive car parking and full promotion of sustainable options for onward journeys, including cycle hire facilities/bus connections.
• Incorporating secure and covered cycle parking to meet long-term demand from occupiers and visitors, in convenient locations to maximise usage, together with consideration of showers, changing facilities, lockers and bike hire scheme parking.
• Adequate provision of designated pick-up/drop-off points for taxis, demand-responsive transport services and car clubs etc.
• Adequate parking and docking facilities for escooters.
• Endorsing mobility credits as incentives to new residents to give up parking spaces, with usage of spaces being kept under review.
• Making appropriate parking provision for deliveries and servicing (including the requirement of Delivery and Servicing Plans for appropriate developments) to help meet road safety requirements, transport emissions and other environmental impact standards and reduce repeat deliveries.
• Promoting controlled parking zones around schools and early years’ settings.

In addition to the above bullet points, consideration should be given to further measures to help manage the overall demand for travel such as the expansion of Controlled Parking Zones, greater use of Traffic Regulation Orders and the role out of permit schemes.

Also where car parks are under-utilised, changes in land uses could be explored including replacing parking provision with mobility hubs, and be adapted to reflect demand, and we have seen this as a policy in other local plans across the region and beyond. Also, any policies which restrict the proliferation of ‘bomb site’ car parks on vacant land would further be welcomed.