Draft Black Country Plan

Support

Representation ID: 45901

Received: 11/10/2021

Respondent: Transport for West Midlands

Firstly LEV’s should be changed to ZEV’s and this should take place across the entire Draft Black Country
Plan.

We fully support this policy but consideration of ZEV charging of public transport infrastructure may also be required for new developments. As part of the BSIP, by 2030, we aim to have nearly 90% of our regions 2,000 strong bus fleet zero emission.

Comment

Representation ID: 45902

Received: 11/10/2021

Respondent: Transport for West Midlands

Whilst we don’t disagree with any of the current policies presented in this chapter, we consider that this policy together with several others including (Transport etc.) need to be much stronger in terms of being clear on the role spatial planning and its relationship with transport demand and travel behaviours plays in achieving net zero and the decarbonization of the transport system, through reducing the wider impacts of travel, including the energy demands of transport.

However, this Climate Change chapter is very much about mitigation and adaptation, as opposed to preventative action, and to fully achieve net zero by 2041 across our region, we must do this at scale and pace.

The WMCA is fully committed to its own WM2041 carbon ambition which means using cars less together with a mix of the following to take place:
• Reductions in the frequency of travel – consolidation of trips or replacement of travel with use of information and communication technologies;
• Changes to where people travel to/from – making shorter journeys and/or to places that are more
easily accessed and served by more sustainable modes of travel; and
• Changing the vehicles used to travel – modal shift to more sustainable modes such as public transport and walking and cycling and switching to personal vehicles that require less energy to use such as smaller cars, personal light vehicles, and micromobility.

Based on the above, under Policy CC1 (1b) it is important that all development, be designed to support rapid decarbonization of transport, and where it may generate additional trips, it should demonstrate that their impact overall, does not result in additional carbon emissions. When the transport modelling work is complete and shared with TfWM, a greater understanding of the true impact of the plan proposals as well as the extent of net carbon increases from transport will hopefully be demonstrated.

Comment

Representation ID: 45903

Received: 11/10/2021

Respondent: Transport for West Midlands

Under policy CC4 Air Quality, paragraph 10.179 should also be expanded to include the following text: “This revised version will need to take into account the current Environment Bill and it’s requirement for new UK targets, to be set by October 2022, for annual average levels of PM 2.5 in ambient air, and for population exposure reduction to PM 2.5. The University of Birmingham-led WM-Air Project, which is supported by West Midlands local authorities and WMCA, will then help inform the development of the new Black Country Air Quality Supplementary Planning Guidance document”

Furthermore, under the Strategic Approach (point 1a) the policy should include public transport and read “the integration of cycling, walking, public transport and electric charging points as part of their transport provision”. Also point 1b should include walking and cycling and read “promoting and supporting (including through continued joint working with authorities outside the Black Country) a modal shift from private motorised vehicles to use of clean, fast and accessible public transport alternatives such as rail, the Metro and bus transport networks and cycling and walking”.

In summary, greater acknowledgement of decarbonizing the transport system is required in this chapter, through ensuring new developments do not result in additional trips and carbon emissions, through using far less energy intensive personal vehicles and more sustainable modes and ensuring our land use policies result in people travelling far less and over shorter distances. Aligning this chapter with that of the transport chapter is therefore imperative, to demonstrate the links transport plays in tackling the climate emergency.

Comment

Representation ID: 45904

Received: 11/10/2021

Respondent: Transport for West Midlands

Under ENV7 Canals (point G), we praise the links and enhancements for off-road walking cycling access but improving general access onto the canal network and integrating it with the wider transport network needs emphasising far more.