Regulation 19 Local Plan (Publication Version)

The Regulation 19 Local Plan outlines locally specific policies and both strategic and non-strategic site allocations to meet the housing and employment needs of Sandwell for the plan period from 2024 to 2041. We note that when adopted, this Local Plan will replace the Black Country Core Strategy (adopted in 2011), the Sandwell Site Allocations and Development Plan Document (the SAD, adopted in 2012) and Area Action Plans for West Bromwich, Smethwick and Tipton. We also note that the Local Plan will incorporate elements of former supplementary planning documents as appropriate and will include details from the West Bromwich Masterplan and Interim Planning Statement. We also note that the Local Plan includes a schedule of policies that remain saved from the previous plans, along with the inclusion of few new policies, as detailed in Appendix N of the Local Plan (Publication Version) document.
National Highways agree in principle to the vision and objectives of the Regulation 19 Local Plan.

Employment and Housing Requirements

Based on our review of the Regulation 19 consultation, we note that the housing and employment requirement has changed since the ‘Regulation 18 – Draft Local Plan’ consultation. It outlines a requirement to deliver 211 hectares of employment land over the plan period. This includes 185 hectares identified in the Economic Development Needs Assessment (EDNA) 2023, with an additional 26 hectares of existing operational employment land reallocated for housing and other uses. The housing demand for the plan period from 2024 to 2041 has slightly reduced to 26,350 dwellings (1,464 dwellings per year), which is less than the earlier projection of 29,773 dwellings (1,489 dwellings per year) during the Regulation 18 consultation. We would welcome clarification from you on whether this is based on the latest housing requirement calculation.

Employment

The Regulation 19 Local Plan aims to deliver c.42 hectares of employment land, leaving a shortfall of 169 hectares.

Upon comparing the site allocations for employment land between the Regulation 18 and Regulation 19 consultations, we note that the allocations remain the same with only one site being removed (Site ID: SEC1-4 during the Regulation 18 consultation).

We note that both employment and housing supply identified in the Regulation 19 Local Plan considers existing planning applications, sites under construction, and windfall allowances.

We acknowledge receipt of the comprehensive assessment report submitted in support of the Regulation 19 consultation and appreciate that you have undertaken an integrated Sustainability Appraisal (SA) and Strategic Environmental Assessment (SEA) to evaluate the different housing and employment growth options. We note that the site allocations have been considered based on the location, the availability of greenfield and brownfield sites, and sustainability, following a ‘Balanced Green Growth’ approach. It is notable that the new development allocations are concentrated within Regeneration Areas and Centres, which is expected to result in a more efficient use of land while enhancing sustainable travel options. This focus aligns with the plan’s broader objectives of promoting sustainable development and supporting local regeneration efforts.

Housing

While the housing demand is set at 26,350 dwellings, the Regulation 19 Local Plan identifies a supply of 10,434 dwellings, leaving an unmet need for 15,916 homes. We welcome the Council's initiative to address this shortfall by working with neighbouring local authorities and Black Country Authorities through the Duty to Co-operate mechanism, which aims to accommodate some of Sandwell’s unmet housing needs within their own housing provision. We look forward to receiving an update on this in due course to understand how the impacts from the unmet housing need will be captured.

Table 7 of the Regulation 19 Local Plan indicates that a total of 8,057 dwellings will come through as allocated sites (including sites under construction and with planning permission). However, when reviewing the site allocation details available in Appendix B, this only reflects a total of 7,717 dwellings. We welcome clarity on the allocations and recommend that you update this in the final version of the Local Plan for consistency.

On comparing the site allocations in the Regulation 19 consultation with those included in the Regulation 18 consultation, we note that a few sites have been added and removed however, we have no comments to make on this.

Sustainable Transport

We acknowledge that the Regulation 19 Local Plan has specifically focussed on policies SCC1 – SCC4 to tackle climate change through a reduction in carbon emissions, improving sustainable modes of transport, and development of energy efficient buildings etc.

We note that the following policies remain the same as stated in the Regulation 18 consultation and we welcome this. Policy STR3 (Managing Transport Impacts of New Development) sets out the need for planning applications to demonstrate how the development ensures adequate accessibility and connectivity, measures to improve sustainable transport, and the requirement to produce a Transport Assessment and Travel Plan where necessary, and we welcome this. References have been made in Policy STR3 on how developers are expected to create an environment that encourages walking, cycling and public transport when designing their schemes.

Policies STR4 (The Efficient Movement of Freight and Logistics), STR5 (Creating Coherent Networks for Cycling and Walking) and STR6 (Influencing the Demand for Travel and Travel Choices) sets guidelines on improving sustainable transport. We appreciate the effort taken in developing these policies and consider this to be aligned with the expectations set out in the National Planning Policy Framework and National Highways’ Net Zero Strategy.

Impact Assessment

As noted in our response during the earlier consultation, any potential sites anticipated to have an impact on the SRN in the area are recommended to be subject to consultation with National Highways, and appropriately assessed in line with the Department for Transport (DfT) Circular 01/2022, to determine the potential impacts on the SRN in the area. Depending on the scale of likely impact on the SRN in the area, the applicant / developer may need to identify suitable mitigation measures (if required). It is to be noted that the cumulative impact of the proposed site allocations also needs to be assessed in line with the Circular for understanding the likely traffic impacts on the SRN in the area, in terms of capacity & safety and identifying any possible mitigation measures (if required).

Black Country Modelling Report

During the Regulation 18 consultation, the ‘Black Country Transport Modelling Report (2023)’ was submitted as part of the evidence base, which included the draft scenario assessments. Following our high-level review, National Highways acknowledged that the modelling exercise would be revised as the Local Plan progresses and provided comments which had to be considered in the full scenario assessment process.

As part of the Regulation 19 consultation, we note that a revised modelling report (dated 2024) is available. We have reviewed this along with the following documents:
1. PRISM6 Model Validation Report
2. PRISM6 Future Year Report
3. Transport Modelling to Support Local Plans within the Black Country (July 2024)
Based on our initial checks, we have the following comments where we seek clarity to help us proceed with the review.

a) Clarification on how the impacts of Covid-19 on forecasts have been accounted for, ideally with reference to the guidance in TAG M4. We note that the report highlights that the previous Local Plan did not account for it, and that this was a red risk factor, but there is no reference to correcting for this, except for asserting that some elements of the lingering effects of Covid-19 are considered as part of NTEM 8.0. That is true, for the Behavioural Change CAS only (ref: Uncertainty Toolkit, para 5.30), but it’s a different issue from assessing whether the base from which forecasting is undertaken needs adjustment (which is what M4 appendix B looks at).
b) Clarification on when NTEM is referred to, which specific version and scenario is being used.
c) Clarification on the forecasting approach: this appears to be presenting the results of a single forecast. In line with the advice in the Uncertainty Toolkit, what was the decision process for not exploring uncertainty?
d) Information on the derivation of any new parameters developed, e.g. how were the parameters for new forecast years created, including the sources of inputs to the parameter calculations.
e) Information that allows us to understand the stability of model outputs, how these change by area, etc. We would expect to see, as a bare minimum, demand model convergence, highway model convergence and stability, and network statistics
(ideally by sector).

We look forward to engaging with you in addressing the above comments to expedite the process.

Infrastructure Delivery Plan (IDP)

During the Regulation 18 consultation, the Infrastructure Delivery Plan (IDP) – Part 1 (Infrastructure Assessment Need) was submitted, which provided an understanding of baseline infrastructure capacity and needs within Sandwell to accommodate the future growth.

As part of the current consultation, we appreciate that an Infrastructure Delivery Plan (IDP) – Part 2 (Infrastructure Delivery Schedule) has been submitted. Table 1 of IDP Part 2 notes that National Highways was consulted by the Council and asked to provide details on any specific transport infrastructure requirements related to the proposed site allocations, including cost estimates. At the time, National Highways indicated that we would confirm the need for mitigation measures following our review of the results of the Strategic Transport Assessment, once completed.

A total of 43 transport infrastructure schemes are included in the IDP Part 2, the majority of which focus on improving active travel and public transport. We acknowledge that specific infrastructure / mitigation requirements are yet to be finalised, as the modelling work associated with assessing the transport impacts of the proposed growth is ongoing. We look forward to receiving the final list.

Policy STR1 of the Regulation 19 Local Plan refers to improvements at M5 Junctions 1 and 2 (Appendix L – Transport Proposals) and we look forward to collaborating with you in identifying feasible mitigation measures.

Duty to Cooperate

For any developments which have an impact on neighbouring Local Authorities (LA), National Highways advises a joined-up approach whereby National Highways, Sandwell and the other Local Authorities attend joint meetings with future developers or applicants. This will ensure that the interests of all parties are protected, and a combined solution is derived.

National Highways will actively work with Sandwell MBC to develop and draft a Statement of Common Ground (SoCG) to deal with any strategic cross boundary issues as the Local Plan progresses.

1. Sandwell 2041: Spatial Vision, Priorities and Objectives

The Trust has no further additions to make to its Regulation 18 observations.

2. Spatial Strategy

The Trust maintains its endorsement of the ‘key issues addressed in the SLP’ but repeats its request that our canal network be included within Figure 2 - Sandwell Spatial Map so that the contribution our network makes towards the delivery of Sandwell’s Spatial Strategy and overall Sandwell Local Plan Vision 2041 can be fully appreciated and realised by citizens and developers alike.

3. Development Strategy

The Trust continues to welcome the retention and enhancement of a canal-specific policy (Policy SNE6) within the Regulation 19 Sandwell Local Plan and as such does not seek the addition of replica canal-specific wording within every other relevant policy wording within the Plan. Cross-referencing to Canal Policy SNE6 however is encouraged where applicable.

We note the inclusion of ‘blue-green infrastructure’ within Policy SDS1 (e) – Spatial Strategy for Sandwell and welcome the retention of canal-related content within the now renumbered Policy SDS3 – Regeneration in Sandwell.

We also maintain our commitment to continued engagement with the Council and partner stakeholders in the delivery of regeneration initiatives within Sandwell which interface with our network, such as those for the Smethwick-Birmingham Corridor Framework and Rolfe Street Masterplans and related SPD’s, as they progress.

Placemaking – achieving well-designed places

The Trust continues to encourage incorporation of cross-referencing to Canal Policy SNE6 within the justification text to now renumbered Policy SDS5 - Achieving Well-designed Places, as well as consultation on any future Local Design Codes.

Cultural Facilities and the Visitor Economy

The Trust welcomes inclusion of the canals within both renumbered Policy SDS6 (point 9) - Cultural Facilities and the Visitor Economy and its justification text, and has no further comments to make on this matter.

Green and Blue Infrastructure

The Trust welcomes inclusion of the canals within now renumbered Policy SDS8 - Green and Blue Infrastructure in Sandwell and its introductory and justification texts, and has no further comments to make on this matter.

4. Sandwell's Natural and Historic Environment

Nature Conservation

In relation to Policy SNE2 – Protection and Enhancement of Wildlife Habitats, the Trust repeats its previous advice that, “the value of the canal network to Biodiversity Net Gain (BNG) will manifest itself as the implementation of BNG gains traction in 2024 and beyond. For example, canals are part of the local Biodiversity Action Plan (BAP) and as such will provide an increasing value and essential role in the Local Nature Recovery Strategy. Canals more broadly play a crucial role within Sandwell for nature conservation and provide large populations of urban dwellers with access to nature. As such Sandwell's canals should be recognised for the crucial role they facilitate in priority species movements and recovery through the West Midlands.”

We continue to seek on-going engagement in the evolution of BNG-related policy wording throughout the plan preparation stages over 2024/5, including at Examination stages and in the correct application of the BNG metric in the assessment of current and future planning applications which suitably interface with our network.

Canals in Sandwell – Policy SNE6

The Trust gratefully notes that all our requested changes to this policy wording have been incorporated with the Regulation 19 version of this policy, and we therefore have no additional comments to make.

The Historic Environment

The Trust continues to welcome mention of ‘the canal network and its associated infrastructure, surviving canalside pre-1939 buildings and structures, and archaeological evidence of the development of canal-side industries and former canal routes’ within Policy SHE2 5(e) – Development in the Historic Environment.

5. Climate Change

The Trust notes that this section of the Regulation 19 version of the Sandwell Local Plan has been substantially rewritten.

Paragraphs 5.13 and 5.61: We welcome the addition of these paragraphs in relation the potential of our network to provide for the heating and cooling needs of forthcoming adjacent development.

The Regulation 18 version and paragraph 5.15 (in relation to retrofitting) appears to have been removed from this section of the Regulation 19 version and therefore our comments on the need to assess development impacts of this in terms of canal setting, historical significance and amenity value are absent. The Trust requests reinstatement of this section and incorporation of this advice, where applicable.

Para 5.71: The Trust welcomes the addition of the canal network within this paragraph in support of Policy SCC5 – Flood Risk.

Para 5.83 Canals and SuDS: The Trust welcomes the addition of the canal network within this paragraph in support of Policy SCC6 - Sustainable Drainage.

6. Health and Wellbeing in Sandwell

The Trust notes that para 6.14 (h) includes reference to blue and green infrastructure, which by Glossary definition includes the canal network. Para 6.46 also adds reference to the canal network, and reference within para 6.50 to the use of planning conditions and obligations to support the work of agencies such as ourselves is further beneficially added.

7. Sandwell's Housing
The Trust previously advised that it, “is content that canal-specific implications arising from the Council’s draft Housing need and supply policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals in Sandwell (as requested amendments above refer). However, inclusion of the canal network within relevant policy and
allocation maps (ACTION REQUEST) will enable developers to identify canal-related constraints at an early stage and engage with us accordingly, ideally at pre-application stage. The Trust therefore requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice from us direct:

https://canalrivertrust.org.uk/specialist-teams/planning-and-design/our-statutory-consultee-role/what-wereinterested-in/pre-application-advice

See also comments on Appendix B below.

In relation to towpath improvement aspirations the Trust has identified the Tame Valley Canal, Walsall Canal and the Old Wednesbury Canal as priority areas for upgrading over the plan period, and will seek to request Section 106/CIL monies from appropriate schemes where they arise in proximity to these stretches of the network.

The Trust also advises that it has some specific critical assets within the Sandwell area such as Spouthouse Embankment, Titford Pools feeder, and Netherton Tunnel which will require careful assessment of allocations for impact and mitigation under the provisions of SNE6 – Canals, particularly in relation to matters of land stability and infrastructure maintenance, cross-referenced with historic coal mining activity within Sandwell.”

We maintain this previous advice and reiterate the importance of fully assessing development proposals under the requirements of Policy SNE6 – Canals.

8. Sandwell’s Economy

The Trust previously advised that it, “is content that canal-specific implications arising from the Council’s draft Economy policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals (as requested amendments above refer). However, inclusion of the canal network within relevant policy and allocation maps (ACTION REQUEST) will
enable developers to identify canal-related constraints at an early stage and engage with us accordingly, ideally at pre-application stage. The Trust requests on-going engagement from the Council on submitted preapplication enquiries, and also encourages developers to seek pre-application advice from us direct:

https://canalrivertrust.org.uk/specialist-teams/planning-and-design/our-statutory-consultee-role/what-wereinterested-in/pre-application-advice (ACTION REQUEST).

See also comments on Appendix C below.”

We maintain this previous advice and restate the importance of fully assessing development proposals under the requirements of Policy SNE6 – Canals.

9. Sandwell's Centres and 10. West Bromwich

The Trust previously advised that it, “is content that canal-specific implications arising from the Council’s draft Centres policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals (as requested amendments above refer). However, inclusion of the canal network within relevant policy and allocation maps (ACTION REQUEST) will
enable developers to identify canal-related constraints at an early stage and engage with us accordingly, ideally at pre-application stage. The Trust requests on-going engagement from the Council on submitted preapplication enquiries, and also encourages developers to seek pre-application advice from us direct:

https://canalrivertrust.org.uk/specialist-teams/planning-and-design/our-statutory-consultee-role/what-wereinterested-in/pre-application-advice (ACTION REQUEST).

See also comments on Appendix D below.”

We note that in places the canal network is now identified within ‘Areas of High Historic Townscape Value’ designations, and on this basis have no further comments to make on this matter.

11. Transport

The Trust previously advised that, “The Section contains a number of polices in relation to transportation, including the promotion of active and sustainable travel through modal shift. The canal network can provide robust opportunities for promotion of these agendas and the Trust welcomes the inclusion of the canal network within sub-section 3 of Policy STR5 – Creating Coherent Networks for Cycling and Walking. However, the Trust requests inclusion of the canal network within Figure 13 - Transport Key Diagram, overlaying with cycle and walking networks, to enable its role in the delivery of sustainable transport and modal shift to be more readily identified in conjunction with the implementation of Policy STR5 – Creating Coherent Networks for Cycling and Walking (ACTION REQUEST).

Similarly, the Trust welcomes mention of encouragement of use of the waterways within sub-section 1 of Policy STR4 – The Efficient Movement of Freight and Logistics as a sustainable alternative to road-based freight movement.”

We gratefully note that our network is now added into Figure 14 – Existing Transport Network and Figure 15 - Transport Improvements Plan and have no further comments to make on this matter.

12. Infrastructure and Delivery

The Trust previously advised, “The Trust welcomes mention of the potential for use of canal towpaths for the provision of 5G network infrastructure within sub-section 3d of Policy SID1 - Promotion of Fibre to the Premises and 5G Networks and requests additional wording as follows, ‘To be delivered through the reasonable use of planning conditions or S106/CIL obligations.’ (ACTION REQUEST).”

We welcome the retention of wording relating to the potential of our network to provide these opportunities within now renumbered Policy SID2 – Digital Infrastructure and paragraph 12.33, albeit without mechanisms for delivery being specified. We therefore repeat our previous advice.

13. Minerals and Waste

The Trust previously advised, “The Trust is content that canal-specific implications arising from the Council’s draft Minerals and Waste policies and allocated sites (identified as being preferentially within Local Employment Sites) can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals (as requested amendments above refer). However, inclusion of the
canal network within relevant policy and allocation maps (ACTION REQUEST) will enable developers to identify canal-related constraints at an early stage and engage with us accordingly. The Trust therefore requests ongoing engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice from us direct:

https://canalrivertrust.org.uk/specialist-teams/planning-and-design/our-statutory-consultee-role/what-wereinterested-in/pre-application-advice (ACTION REQUEST).

See also comments on Appendix E and Appendix F below.”

We maintain this previous advice and restate the importance of fully assessing development proposals under the requirements of Policy SNE6 – Canals.

14. Development Constraints and Industrial Legacy

We previously advised, “The Trust is content that canal-specific implications arising from the Council’s draft Development Constraints and Industrial Legacy policies can be adequately addressed through the issues specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals (as requested amendments above refer). Accordingly, we request the incorporation of cross-referencing to Canal Policy SNE6 within the introductory text to this section, for example after para 14.5. or more specifically in the justification texts for Policies SCO2 - Pollution Control and Policy SCO3 - Land contamination and instability (ACTION REQUEST).

Similarly, we request para 14.17 of the justification text lists potential receptors of light pollution impact and includes the canal network within that list. (ACTION REQUEST).”

We note that paragraph 14.18 is added which reflects impacts to our network specifically, and therefore have no further comments to make on this matter.

15. Development Management

We previously advised, “The Trust is content that canal-specific implications arising from the Council’s draft Development Management policies can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy SNE6 - Canals (as requested amendments above refer). Accordingly, we request the incorporation of cross-referencing to Canal Policy SNE6 within the introductory text to this section, or more specifically in the justification texts for Policy SDM1 – Design Quality, Policy SDM2 – Development and Design Standards, and Policy SDM3 – Tall Buildings and Gateway Sites.

In relation to design quality, the canal network also presents opportunities for positive placemaking and the reduction of anti-social behaviour as commented on above in relation to Policy SDS4 - Achieving Well-designed Places.

In relation to tall buildings and gateway sites the Trust requests that Policy SDM3 – Tall Buildings and Gateway Sites sub-heading 5(c) specify that this relates to both designated and non-designated heritage assets (ACTION REQUEST).

The associated justification text should also contain reference to the need for impact of tall buildings within typically lower height profile canal environments to be a material consideration, to enable assessment of impact on the prevailing visual environment and character of the canal network (ACTION REQUEST).”

We note that reference to our network is added into Policy SDM1 (h) – Design Quality and paragraph 15.17 and into Policy SDM3 (c) – Tall Buildings and Gateway Sites, and therefore have no further comments to make on this matter.

Delivery, Monitoring, and Implementation

We previously advised, “The Trust requests opportunity to engage with the Council on an on-going basis throughout the plan period to secure the benefits to the canal network envisaged by the Plan’s suite of policies (ACTION REQUEST).

Furthermore, the Trust notes that use, delivery and monitoring of Section 106 and CIL payments is not included within the policy wording and queries its absence (ACTION REQUEST).”

The Trust reiterates this previous advice.

Errata Sheet

The Trust has no comments to make on this matter.

APPENDIX A – Nature Recovery Network and Biodiversity Net Gain

The Trust previously advised, “The Trust seeks to maintain engagement with the Council on the evolution of BNG delivery within Sandwell in its forthcoming formative roll-out stages (2024/25) and thereafter on an implementation basis throughout the plan period (ACTION REQUEST).”

The Trust maintains this previous advice, on an on-going basis through the Development Management process.

APPENDIX B - Sandwell Site Allocations

SH7 - The Boat Gauging House and adjoining land, Factory Road, Tipton – development proposals should have particular regard to the heritage assets on site in scale, form and impact on character. The Trust requests clarification of the continued inclusion or deletion of this allocation. We note the additional of our requested wording to all other allocations, and therefore have no further comments to raise to those other allocations.

APPENDIX C – Employment Allocations – vacant land

SEC1-10 - Brandon Way/ Albion Road - development proposals where adjacent to the canal should have full regard to the land stability issues of the canal. The Trust requests clarification of the continued inclusion or deletion of this allocation.

APPENDIX D – West Bromwich Masterplan and Carter's Green Framework Plan (now Masterplans)

The Trust welcomes substantial reference to the canal network now within this Appendix, and seeks continued engagement through the Development Management process to ensure effective delivery.

APPENDIX E – Strategic Waste Sites

We previously advised, “The Trust notes the identification of the existing Strategic Waste Sites within the Black Country authorities, (rather than just Sandwell) and raises no additional comments subject to statutory consultation on any forthcoming planning applications on any of these sites within our notified areas, and assessment in line with the emerging Policy SNE6 - Canals (for any sites within Sandwell) if applicable.” The Trust maintains this previous advice.

APPENDIX F – Minerals

We previously advised, “The Trust notes the identification of existing Key Mineral Infrastructure sites and raises no additional comments subject to statutory consultation on any forthcoming planning applications on any of these sites within our notified areas, and assessment in line with the emerging Policy SNE6 – Canals, for sites within Sandwell, if applicable.“

The Trust maintains this previous advice.

APPENDIX G – Site allocations - changes

We previously advised, “The Trust notes the changes in allocations, largely from housing to employment uses, and raises no additional comments subject to statutory consultation on any forthcoming planning applications on any of these sites within our notified areas, and assessment in line with the emerging Policy SNE6 - Canals.

It is noted that in principle some employment uses may give rise to additional assessment needs and mitigation requirements in relation to operational pollution control e.g. air and water quality.”

The Trust maintains this previous advice.

APPENDIX H – Rowley Hills

The Trust has no additional comments to make on this matter.

APPENDIX I – Sandwell Local Plan Housing Trajectory

The Trust has no additional comments to make on this matter.

APPENDIX J – Sandwell Playing Pitch and Outdoor Sports Strategy (extract) (now Open space and play provision standards for development)

The Trust has no additional comments to make

APPENDIX K – Transportation Policy

The Trust has no comments to make on the proposed parking standards.

APPENDIX L – Transport Proposals

The Trust has no additional comments to make subject to assessment in line with Policy SNE6 – Canals.

APPENDIX M – Sandwell’s Historic Environment Designations

The Trust has no comments to make on this matter.

APPENDIX N – Superseded Policies and Plans

The Trust has no comments to make on this matter.

APPENDIX O – Glossary

The Trust has no comments to make on the proposed definitions.