Black Country Core Strategy Issue and Option Report

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.

Thank you for inviting comments on the Draft Black Country Core Strategy: Issues and Options consultation. The comments in this response represent the views of Transport for West Midlands (TfWM) - the transport arm of the West Midlands Combined Authority.
We welcome the opportunity to respond to this consultation, given the strategic importance of the Black Country and the key role it plays in delivering the growth agenda, meeting future economic and housing demand and in attracting and retaining investment. It is vital therefore that the Black Country is able to provide the necessary infrastructure and high quality transport links across its four local authorities, around the wider West Midlands and beyond.
WMCA Strategic Transport Plan "Movement for Growth"
As a body delivering regional transport, we are pleased to witness clear referencing and alignment of the West Midlands Combined Authority's (WMCA) Strategic Transport Plan "Movement for Growth" (MfG) with the Core Strategy. MfG is the long term, overall transport strategy document for the West Midlands and supports the Combined Authority's "umbrella" Strategic Economic Plan. MfG together with TfWM's 10 year Delivery Plan will be the guiding documents for other localised transport plans and will help drive strategic transport decisions, along with public transport and active travel measures across the wider region.
The draft Black Country Core Strategy is fully supported by TfWM as its approach for growth and development is clearly underpinned by a sustainable transport system, in accord with our existing policies. There are, however areas where TfWM would welcome positive partnership working with the Black Country, to develop further a sustainable transport approach of the plan, to accommodate the scale of new development planned and support its future growth and prosperity. Our comments for each chapter are now highlighted below:
2: The Black Country Today - The Existing Strategy
In tables 3 and 4, TfWM would like to see all three HS2 Connectivity package SPRINT routes schemes included. These should include the Hagley Road Extension (Halesowen, 2), Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City Centre scheme.
3: The Strategic Challenges and Opportunities
Within table 1 (Evidence Base for the Black Country Core Strategy Review), TfWM welcomes
reference to the Strategic Transport Plan "Movement for Growth" but does however suggest
that reference is made to TfWM's 10 Year Delivery Plan (detailing transport schemes and
programmes), the HS2 Growth Strategy and the Black Country Rapid Transit Study. All three
documents should also be included in the evidence base and be referenced in policies TRAN1
-TRAN5.
Concerning key issue 2: 'Meeting the housing needs of a growing population' whilst we
encourage development close to railway stations, we appreciate that this is not always
possible. Therefore improved connectivity to stations/interchanges should also be noted,
especially for housing and employment sites proposed afar from existing railway stations,
with all new housing being inclusive of cycling connectivity.
Finally in terms of Key Issue 6 'Reviewing the role and extent of the green belt', TfWM suggest
reference is made to the importance of public transport options for development in the
greenbelt, together with the importance of strategic park and ride sites serving greenbelt
areas.
4. Reviewing the Strategy to Meet New Challenges and Opportunities
Throughout this chapter, more emphasis needs to be placed on cycling and walking together
with public transport, especially in terms of access to new housing and employment
development. We feel the Core Strategies vision should reflect all modes. Therefore there
should be greater recognition for how active travel could support the Black Country's growing
population and the challenges of capacity felt on the road/rail network.
In terms of delivering efficient public transport, priority as well as capacity for SPRINT and
conventional bus services should be given equal priority. Accommodating additional services
and making them more reliable is often much harder to achieve than putting on more
services. Therefore priority measures for public transport should be much more prominent in
the draft Core Strategy than is currently.
When deciding on the location of new developments, consideration to existing cycling
infrastructure such as canals and greenways should be clearly part of the criteria of decision
making. Also where cross boundary developments do occur cycling and walking
infrastructure should be of a similar standard, across all local authorities (those within the
Black Country or bordering it) and all should agree to the Cycle Charter principles, to provide
regional consistency. TfWM are currently working with the 'Shire Counties' to agree a more
unified regional wide approach to cycling.
More consideration should also be paid to active travel opportunities on localised journeys.
In particular, TfWM would like active travel needs to be designed into street design and layout
from the onset to form a 'Healthy Streets Approach' as promoted by Transport for London.
It should also address any local challenges to cycling such are safety issues, cycle facilities,
topography and behaviour change, for example. TfWM are producing a Health and Transport
Strategy which recognises the way people travel is an important part of physical and mental
health. Opportunities for greater levels of physical activity during travel can reduce obesity
and associated conditions such as heart disease or strokes. Therefore, more emphasis should
be placed on active travel - especially those being adopted as part of the canal improvement
programme and strategic cycleways on the highway.
Within this chapter, there is also no reference to addressing the wider issues relating to air
quality. In light of the Governments recent New Air Quality Plan, it is vital the Core Strategy
picks up on air quality and matters relating to this and that any land use changes help to
improve air quality and not worsen these problems. Where schemes could reduce air quality,
appropriate redesign and/or effective mitigation should be considered along with the
importance of changing people's behaviour so that they use cleaner transport options.
In terms of supporting employment and housing growth, 'continuing the role of the growth
network' is a more favoured approach by TfWM but we appreciate that other options may
need to be explored. If extending into the greenbelt is required, either within multiple smaller
settlements (Option H1) or a limited number of large settlements (Option H2), we need to
secure significant infrastructure improvements to support such development. Option H2 in
particular, with more large scale developments such as SUEs could secure the necessary
infrastructure improvements whereas option H1 may not justify large scale transport
improvements and encourage only increased car usage.
However each proposed greenbelt location would need to be evaluated individually as to the
public transport requirements. Some locations may just need adjustments to existing
services, whereas others may involve extensive new networks to the green belt.
Nevertheless, for any option it is vital adequate public transport along with active travel
modes are considered from the offset and locations are considered first in terms of their
access by the canal network/greenways for cycling/walking.
In terms of IA - IB, H1 - H2 and E1 - E4 options, TfWM feel that public transport along with
active travel infrastructure should be mentioned in the key challenges and opportunities
table. Places located in the greenbelt will be more remote, and the importance of better,
multi modal integration should be included in the required infrastructure. TfWM would also
welcome positive partnership working with the Black Country, to develop the required
sustainable transport approach and support future growth and prosperity.
5. Delivering Growth - Infrastructure and Viability
In terms of the location of affordable housing, greater consideration needs to be paid to active
travel and public transport. In some instances, people may not be in a position to own a car
and will rely on good public transport to access key opportunities.
The Black Country Core Strategy also places a high emphasis on rail and mass-transit, but it is
unlikely that this infrastructure will be viable to meet all the Black Countries development
needs. The strategy should not lose sight of the conventional bus network (providing 4 in
every 5 public transport journeys across the Black Country) which offers route flexibility and
is responsive to change. Moreover, where there may not be the justification for investing in
rail/mass-transit infrastructure new bus routes can be planned to connect new communities
and support housing and jobs growth.
TfWM are also committed to delivering Network Development Plans (NDP) across the Black
Country to ensure that the bus network continues to meet local needs and adapts to meet
future development opportunities. NDP's take a long-term, spatial approach to planning the
bus network which will support the Core Strategy, including analysing development quanta
and phasing and in fulfilling any potential future growth. Buses, therefore, play a vital tool in
supporting plan-making and should not be under played in the Core Strategy. This would
mean including a core high frequency strategic bus network within the transport diagrams
and within key transport polices and demonstrating the importance of bus priority measures.
6. Review of Existing Core Strategy Policies and Proposals
Sprint
In terms of section E: 'The Black Country Transport Network' we strongly recommend that
specific reference to Sprint Bus Rapid Transit be made, as this is seen as a priority to connect
the Black Country to HS2. Also paragraph 6.1.38 should refer to A456 to Halesowen rather
than Quinton, which is referred to as the Hagley Road Extension (Halesowen, 2) as well as
Hagley Road Extension (Dudley to Birmingham) and the (A34) Walsall to Birmingham City
Centre.
As Sprint on the A34, A456 and to Dudley are all included in the HS2 Connectivity Package and
HS2 Growth Strategy, they should therefore feature as a priority in paragraphs 6.1.36 / 37 /
38 and in table 3: 'Overview of Potential Changes to Existing Core Strategy Policies'. The
importance of Bus Rapid Transit Park and Ride sites should also be included in this section.
West Midlands Rail
In terms of rail, West Midlands Franchise Award could see a number of rail improvements
serving the Black Country, starting from the 10 December 2017 through to March 2026. This
would include more trains between Birmingham and Wolverhampton and Birmingham to
Walsall including a new direct service between Walsall and London. Concerning the Snow
Hill lines (and subject to wider feasibility studies), services could call at a new station at Merry
Hill together with a new station at the West Midlands Safari Park. Also, the new Franchise
would support the operation of services along the Walsall - Wolverhampton line, calling at
new stations including Darlaston and Willenhall. Despite many of these improvements being
subject to further feasibility work, it is recommended they be referenced in the strategy.
Key Route Network
Where the 'Principal Road Network' has been referred to, should this be changed to the 'Key
Route Network'. In particular in paragraphs 6.1.24 and 6.1.40.
Greater clarity regarding the West Midlands Key Route Network (KRN) should also be included
in the Draft Core Strategy. The KRN covers some 600km of road network (about 7% of the
total WM network but carries 50% of all traffic) and incorporates the major local roads
including:
 roads making up the designated Primary Route Network;
 all local roads serving motorway junctions;
 main roads forming part of or principal bus network or used by highfrequency
bus services; and
 roads serving major education and employment sites.
Although our local highway authorities retain operation and maintenance powers on the KRN,
they have delegated the management arrangement to TfWM and we must ensure effective
flow of traffic on the KRN. It is also essential that we monitor and report on network
performance and develop policies and strategies. Therefore, we must ensure efficient
operation of the KRN is not prejudiced by development - whether it is directly through the
impacts of traffic generation; or through poor coordination/planning of works to deliver the
development.
Bus Standards
It is important that any development should NOT have a detrimental effect on the flow of
buses and respect the below policy within MfG:
 Ensuring town centre access for core bus routes facilitates their minimum commercial
speed of 16 km per hour am peak journey times;
 Ensuring town and city centre access for SPRINT Bus Rapid Transit lines facilitates a
minimum commercial speed of 20 km per hour am peak for proposed SPRINT routes.
Other areas of interest
In paragraph 6.1.36, reference should be made to Highways England Junction improvements
for cycling (currently in feasibility development), other cycle highway schemes and
cycling/walking links to rail stations/interchanges. Also the significant improvements being
made to canals is a step change for the region in making cycling easier and should be
referenced in this section.
In terms of the Policy Area E - The Black Country Transport Network text should include the
HS2 Growth Strategy as well as the HS2 Connectivity Package.
Finally, where the government's DaSTS is now out of date, the Department for Communities
and Local Governments 'Transport evidence bases in plan making and decision taking' should
be referenced, to ensure an appropriate assessment of the transport implications are
undertaken when reviewing the Local Plan.
Summary
TfWM supports the vision for the Black Country as contained within the Draft Core Strategy
and broadly support its aims and policies. Key areas of interest are:
 TfWM's 10 Year Delivery Plan, the HS2 Growth Strategy and the Black Country Rapid
Transit Study should all be included in the evidence base and be referenced in policies
TRAN1 -TRAN5;
 More emphasis should be placed on the importance of sustainable transport options
within the housing, employment and green belt areas, to support new development
in periphery locations. For example bus priority measures, enhanced walking and
cycling measures and reference to all three SPRINT Bus Rapid Transit schemes should
all be included in the transport policy sections;
 When deciding on the location of developments, consideration to existing cycling and
walking infrastructure such as canals and greenways should be clearly part of the
criteria for development, especially concerning development in the greenbelt;
 In terms of the development options, sustainable travel modes must be mentioned in
the challenges and opportunities tables for all options. TfWM would also welcome a
close partnership approach, in developing the required transport to support growth.
 Reference should be made to 'Bus Network Development Plans' to ensure the bus
network fully supports all proposed developments across the Black Country; and
 Finally, reference should be made to issues like air quality, clean air zones and healthy
streets.
Local Plan Delivery
We would like to further reiterate our support for the partnership approach that has been
taken to addressing the strategic transport needs of the plan and the wider area and would
welcome further dialogue as this plan develops.
We would also offer any support required in developing a comprehensive infrastructure plan
that enables the successful delivery of the plan. This will clearly need to relate to ongoing
work schemes within the 10 Year Delivery Plan, in line with the Strategic Transport Plan. The
early development of this infrastructure plan will give potential investors confidence and
allow funding and financing packages to be developed and is therefore a crucial piece of
supporting evidence.