It refers to the Strategic Road Network. However, this does not acknowledge the Major Road Network or Key Route Network. When describing the road network it should be noted that the WMCA have recently begun a review of the Key Route Network (KRN) and subject to approval, the following changes will affect Sandwell. These being:

• Removal of the B4171 Birmingham Road from its junction with A4100 Henderson Way (Rowley Regis) to its junction with A459 Castle Hill (Dudley)
• NEW KRN: Sandon Road from junction with A4030 Bearwood Road to its junction with A4040 Barnsley Road

Discussion – Responses of the Police and Crime Commissioner for West Midlands (PCCWM)

Sandwell Spatial Portrait – paragraphs 27-77 and Challenges and Issues – paragraph 78

This section of the draft Local Plan sets out the background to the Borough and includes key statistics. There is no reference at all in paragraphs 27 to 77 of the crime statistics for the Borough, whereas statistics/ profiles are given for health, economy and skills, employment, transport, broadband and 5G etc. This is considered a significant omission, given crime and disorder are key indicators of relevance in painting a spatial portrait of the Borough. Indeed, it is noted in the accompanying Sustainability Appraisal under Table 2.1: Summary of SA Objectives confirms under point 11 that the reduction of poverty, crime and social deprivation and secure economic inclusion are a Sustainability Appraisal objective, however, no crime statistics are provided against which to measure the success of the objectives. Furthermore, Table 9.1 of the Sustainability Appraisal includes in its recommendations at (11) Equality, ensuring that development proposals take into account crime and safety, and promote safe and accessible neighbourhoods, helping to reduce crime and fear of crime. These recommendations need better translating into the policies of the draft Sandwell Local Plan.

An understanding of the crime profile of the Borough, in accordance with the requirement under paragraph 130(f) of the NPPF 2023, ensures that planning policies and decisions, amongst other requirements, “…create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.”

In this respect, it is considered that the crime profile should be included, and to that end, the existing crime statistics from West Midlands Police (2022), i.e. the last full calendar year, are set out below. The Office for National Statistics (ONS) population projections indicate that the expected number of households across the West Midlands for 2022 was 1,163,039. For the Sandwell area alone, the projected number of households is 129,512.

In 2022, the total number of recorded Police incidents (i.e. those occasions when West Midlands Police were called upon to deploy 1 or more Officer(s) to an incident) was 635,972 for the entire force area. The actual number of crimes recorded, resulting from these incidents, was 364,950 crimes (which equates to 0.55 incidents/0.31 crimes per household, across the entire WMP force area).

The table below sets out these figures, along with those incident and crime figures relating to Sandwell by way of comparison, as highlighted, which coincidently are very similar to the incidents/crimes per household for the whole force area.

Table 1: Crime Statistics from 2022 (See attachment)

On the basis of the above crime statistics, the following proportional factor can be applied to reliably predict the potential additional incidents/crimes which would be likely to occur within a calendar year upon completion as a result of the planned new population growth in the borough of Sandwell.

The proposed numbers of new homes of 11,167 (supply) and 29,500 (need) would represent 8.5% and 22.8% increases in the number of households within Sandwell, respectively. If the same percentage increases are applied to the actual incident and crime statistics for the area, the predicted proportional additional and total incidents/crimes likely to occur within a calendar year are as set out in the following table.

Table 2: Predicted Crime Statistics (See attachment)

As set out in the Arup ‘Infrastructure Delivery Plan Part 1: Infrastructure Needs Assessment
Reference: v2.0 dated 2nd November 2023:

• Sandwell has seen a 25% increase in recorded crime since 2020;
• The demands placed on the police service can increase as the local population increases;
• The demands on the police are exacerbated by the major changes in the nature of crime and methods needed to deal with it, particularly regarding cybercrime, child sex exploitation and terrorism;
• Based on analysis of WMP’s crime statistics (2022), it is predicted that the rising population
would require the recruitment of c120 extra staff members;
• As Sandwell’s population increases, there is a greater need to ensure new development is supported by adequate policing infrastructure in the interest of creating sustainable communities;
• This highlights the importance of new developments employing Secured by Design principles to reduce the amount of additional crime generated as the population grows in certain areas.
The PCCWM clearly has a statutory duty to secure the maintenance of an efficient and effective police force for its area and, of course, the Council is also statutorily required to consider crime and disorder and community safety in the exercise of its duties with the aim of achieving a reduction in crime (ref. Section 17 of the Crime and Disorder Act 1998).

The PCCWM requests that in accordance with national planning policy, the theme of community safety and crime prevention is given greater prominence in the draft Sandwell Local Plan consultation, including in the Spatial Visions, Priorities and Objectives (Chapter 1), to promote improvements in community safety, reducing crime, fear of crime and anti-social behaviour, which are vital objectives in the context of creating sustainable communities. There should also be reference in ‘Challenges and Issues’ (paragraph 78) to crime and disorder.

Policy SDS4 - Achieving well-designed places

The PCCWM supports the requirement at Policy SDS4 point 6 that ‘Development should contribute positively to creating high quality, active, safe and accessible places.’ And at point 7 that ‘To support the development of safe neighbourhoods, ensure quality of life and community cohesion are not undermined and minimise the fear of crime, the design of new development should create secure and accessible environments where opportunities for crime and disorder are reduced or designed out.’

In addition, the justification to the policy at paragraph 3.58 confirms the environmental, economic and social benefits, including community safety, of designing high-quality places.
However, the PCCWM objects to the omission of any reference to ‘Secured by Design’ principles and the ‘Park Mark’ parking standards, which would ensure a consistency in designing out crime. Secured by Design is proven to reduce crime and anti-social behaviour by 87% - see Police Scotland research: Secured by Design - The success of Secured by Design – Police Scotland’s Stuart



Ward showcases extraordinary 87% reduction in crime in Secured by Design properties

Park Mark facilities have seen vehicle-related crime drop by 80%: ParkMark - About The Scheme

It is recommended that the following modification to the policy (shown in bold) be included after Point 7 of Policy SDS4:

‘All new development should include consideration of crime prevention measures, Secured by Design, Park Mark principles, and the need for a maintenance plan to reduce crime, the fear of crime and anti-social behaviour.’

Policy SDS5 - Cultural Facilities and the Visitor Economy

The PCCWM highlights the need to consider the threat of terrorism and measures to minimise crime and anti-social behaviour which can be associated with large gatherings, such as in town centres, under the remit of Policy SDS5. All locations which will generate crowds in public places should consider the need for appropriate security measures in the design of buildings and spaces. Good counter-terrorism protective security can also support wider prevention.

Policy SDS5 is considered to be one measure to achieve Strategic Objective 7 (ensuring communities in Sandwell are safe and resilient and social cohesion is promoted and enhanced) and Objective 11 (to ensure new development supports health and wellbeing).

The PCCWM supports the inclusion of the following wording in Policy SDS5 (point 5), which take on board the previous representations made on behalf of the WMP in respect of Policy CSP5:

‘An assessment should be undertaken (as part of the design of new developments likely to attract large numbers of people) to demonstrate and document how potential security and crime-related vulnerabilities have been identified, assessed and where necessary, addressed in a manner that is appropriate and proportionate.’

However, the justification to the policy does not reference the background to this wording and why it has been included. It is requested that the justification takes account of, and references, the following policy background:

• Planning Practice Guidance (Paragraph: 011 Reference ID: 53-011-20190722 revised 22nd July 2019) recognises that for all locations which will generate crowds in public places, consideration should be given to appropriate security measures in the design of buildings and spaces. Good counter-terrorism protective security can also support wider prevention. The PPG identifies a number of sources of guidance in this respect including ‘Protecting Crowded Places: Design and Technical Issues’, which refers to ‘Secured by Design and ‘Safer Parking’ standards, ‘National Counter Terrorism Security Office (NaCTSO)’ crowded places and ‘Centre for the Protection of National Infrastructure (CPNI)’ built environment guidance.



The PPG goes onto advise that as well as the above referenced guidance, local police Counter Terrorism Security Advisors (CTSAs) and Designing Out Crime Officers (DOCOs) have training and experience of advising on security, are independent in their advice and have further access to more specialist resources where required, including the NaCTSO and the CPNI), and states that local planning authorities should consider referring appropriate planning applications for public access buildings and spaces to the police who will determine the appropriate specialist input (Paragraph: 012 Reference ID:53-012-20190722 revised 22nd July 2019)

• The National Planning Policy Framework (NPPF) is clear in its requirement that local planning authorities should anticipate and address possible malicious threats, especially in locations where large numbers of people are expected to congregate. It states at paragraph 97 that, ‘Planning policies and decisions should promote public safety and take into account wider security and defence requirements by: a) anticipating and addressing possible malicious threats and natural hazards, especially in locations where large numbers of people are expected to congregate. Policies for relevant areas (such as town centre and regeneration frameworks), and the layout and design of developments, should be informed by the most up-to-date information available from the police and other agencies about the nature of potential threats and their implications. This includes appropriate and proportionate steps that can be taken to reduce vulnerability, increase resilience and ensure public safety and security.’

The footnote to the above paragraph confirms this includes transport hubs, night-time economy venues, cinemas and theatres, sports stadia and arenas, shopping centres, health and education establishments, places of worship, hotels and restaurants, visitor attractions and commercial centres.

Accordingly, the justification to Policy SDS5 should be expanded to include the requirement for point 5.

Policy SHW1 – Health Impact Assessments

The PCCWM notes the Council’s acknowledgement (in the preamble to polices on health and wellbeing, e.g. paragraph 6.6) of ensuring a healthy and safe environment that contributes to people’s health and wellbeing being a key Council objective and its partners in the health, voluntary and other related sectors.

The proposed Health Impact Assessments (HIA) cover an assessment of how proposed development will be, inter alia, ‘…inclusive, safe, and attractive, with a strong sense of place, encourages social interaction and provides for all age groups and abilities’ (paragraph 6.14).

The PCCWM supports the policy and its objectives.



SHO1 – Delivering Sustainable Housing Growth

The need for contributions towards Police infrastructure to ensure sustainable growth

In order to sustain the level of growth proposed in the draft Sandwell Local Plan consultation and to meet the national and local policy objectives relating to safety and security, contributions will be required through CIL/ S.106 agreements to help fund the provision and maintenance of Police services to create environments where crime and disorder and the fear of crime do not undermine the quality of life or social cohesion. The PCCWM objects to Policy SHO1 as it should include reference for the need for contributions for social, environmental and physical infrastructure to support sustainable housing growth in accordance with the aspirations of the policy and the plan – however point 4 of the Policy states ‘The development of sites for housing should demonstrate a comprehensive approach, making best use of available land and infrastructure and not prejudicing neighbouring uses.’

As set out elsewhere in this representation, in the comments of the PCCWM on the Sandwell Spatial Portrait and Chapter 12 ‘Infrastructure and Delivery’, a growth in housing and population in the Borough will bring increased demand for police services and there is a need for developer contributions to fund that growth for the reasons set out.
Therefore, new development, including larger housing sites/ housing allocations, should be subject to CIL/ S.106 agreements as appropriate to help fund the provision and maintenance of Police services, and the requirement for this infrastructure should be enshrined in the wording of Policy SHO1.

Of note, point 5 to Policy SHO1 refers to ‘ancillary uses appropriate for residential areas’ in sites with existing planning permission, sites allocated for housing by the Plan and windfall sites, in tacit acknowledgement that such uses as health facilities, community facilities and local shops are linked to housing development and that there may be a gap in provision. However, funding for such community services as policing is necessary and contributions should be required through CIL/ S.106 agreements to help fund the provision and maintenance of, inter alia Police services to create environments where crime and disorder and the fear of crime do not undermine the quality of life or social cohesion.

Proposed housing allocations

The PCCWM requests that the following police sites are considered for residential allocation in the draft Sandwell Local Plan. All sites are owned by the PCCWM.

Table 3 – PCCWM - proposed housing allocations (See Attachment)

SHO2 – Windfall Developments

Under Policy SHO1, windfall housing is to deliver 1,868 dwellings during the plan period. In order to sustain the level of growth proposed in the draft Sandwell Local Plan consultation and to meet the national and local policy objectives relating to safety and security, contributions will be required through CIL/ S.106 agreements to help fund the provision and maintenance of Police services to create environments where crime and disorder and the fear of crime do not undermine the quality of life or social cohesion. The PCCWM objects to Policy SHO2, as it should include reference for the need for contributions for social, environmental and physical infrastructure to support windfall development. Windfall development, as well as development on larger sites/ allocations, should be subject to CIL/ S.106 agreements to help fund the provision and maintenance of Police services, and the requirement for this infrastructure should be enshrined in the wording of Policy SHO2.

The Council’s attention is also drawn to the comments of the PCCWM on the Sandwell Spatial
Portrait and Chapter 12 ‘Infrastructure and Delivery’.

Policy SHO8 – Houses in Multiple Occupation

The PCCWM supports the wording of the policy and justification to Policy SHO8, which reflects the representations made to the Sandwell Issues and Options consultation.

The PCCWM supports the specific reference within the policy itself, point 3(e) as follows -

‘3. Once the current level of HMO provision has been established in a relevant area, the following criteria will be applied to a new proposal:…

e) the development would not give rise to unacceptable adverse cumulative impacts on amenity, character, appearance, security, crime, anti-social behaviour or the fear of crime.’

The PCCWM also fully supports the footnote to this policy which recommends that pre-application and planning application advice is sought for HMO proposals from the West Midlands Police Design Out Crime Officers.

In addition, the PCCWM supports the reference in point 6 of the Policy that states that the policy criteria will also apply to the intensification or expansion of an existing HMO.

The justification to Policy SHO8, paragraph 7.54(g) is also supported by the PCCWM. It explains that harmful impacts associated with high numbers of HMOs can include: ‘…g) increased anti-social behaviour and fear of crime resulting from the lifestyles of some HMO occupants, the transient nature of the accommodation and inadequately designed / maintained properties;…’



However, in addition to the support for Policy SHO8, the PCCWM suggests there is a Borough wide Article 4 Direction introduced to seek to remove the permitted development right to convert a residential dwelling to a small HMO (providing living accommodation for 3 to 6 unrelated persons), such that planning permission would be required for any proposals, alongside the proposed policy against which all HMO applications, as well as planning applications for large HMO (for which there are no permitted development rights and thereby planning permission is required) will be assessed. This is an approach taken by a number of the West Midlands authorities, including Birmingham City Council and Coventry City Council.

An Article 4 Direction regarding permitted development for HMOs, alongside the proposed policies of the draft Sandwell Local Plan will manage the distribution and delivery of HMOs, to reduce the potential harm that arises from the over-concentration and poor quality of HMOs, and the consequential impact this has on crime and disorder and to community safety, and the increased pressure this places on Police resources.


Policy SHO10 – Accommodation for Gypsies and Travellers and Travelling Show people

The PCCWM supports the wording of the policy and justification to Policy SHO10, which reflects the representations made to the Sandwell Issues and Options consultation.

The PCCWM supports the specific reference within the policy itself, point 6 as follows -

‘6. Proposals should be well designed and laid out in accordance with Secured by Design
principles as set out in Policy SDM1.’

The justification to Policy SHO10, paragraph 7.70, that pitches and plots are well designed in line with Secured by Design principles, and that advice is sought from West Midlands Police Design Out Crime Officers is also supported by the PCCWM.

Policy SCE1 - Sandwell Centres

Sandwell’s Local Plan Vision 2041 includes the following:

‘Sandwell’s town centres thrive by day and by night, with an expanded range of retail, leisure and socialising opportunities as well as acting as the foci for new residential developments, community activities and social enterprises. They are safe, welcoming and accessible locations during both day and night, designed to encourage positive public interactions and minimise antisocial behaviour.’

Strategic Objective 15 supports Sandwell’s towns and local centres as places for economic, residential and cultural activity with good access to services, in ways that protect their heritage, character and identity vision is echoed in other policies, for example, paragraph 3.20 confirms that Sandwell is committed to the regeneration of its towns and employment areas and has adopted its



Sandwell Regeneration Strategy 2022-27 that sets out exactly how this will be achieved. The strategy contains a vision for this process, which includes reference to creating ‘exciting, busy, and green centres where people meet throughout the day, with a thriving cultural and night-time economy’. The strategic approach for the Borough’s economic and regenerative growth is set in Policy SDS2 (para 3.21) and Policy SCE1 ‘Sandwell’s Centres’ (paragraph 9.9) that confirms that the Council will support the evening economy, as well as reference to creating evening/ night-time offers in individual polices relating to all the Town Centres, e.g. Policy SWB1 ‘West Bromwich Town Centre’ etc.

However, the PCCWM considers it prudent to include more detail in Policy SCE1 to cover specific issues in relation to the evening economy, to ensure development proposals, particularly in dense areas such as town centres, promote safe and accessible neighbourhoods, helping to reduce crime and the fear of crime.

The PCCWM considers it vital that a proposed expansion of the evening economy should include reference to town centres being safe and secure environments to enable the attainment of that vision. Such a policy should also consider supporting the use of the ‘Secured by Design’ scheme in relation to crime prevention. The aim/ vision should be to reduce crime, the fear of crime, anti- social behaviour and potential disturbance to existing businesses and people. If crime, or the fear of crime is not addressed, people will not feel safe, are unlikely to use the entertainment/night-time facilities, with potential of an economic spiral of decline. Bars, restaurants and shops will close and be boarded up, resulting in less people being attracted to the area, leading to the closure of more premises and companies going out of business. Such a policy would deliver economic, social and environmental sustainability, meeting the objectives of Policy SDS2 ‘Regeneration Areas’ and others. Without a specific policy, the objectives and the vision set out in the draft Local Plan is not met.

The PCCWM notes that Policy SCE1 seeks to meet the Strategic Objectives 2 (sustainable development) and 15 (supporting the town centres). Within the policy itself it is noted that it is proposed to diversify and repurpose centres, enhanced by appropriate complementary uses, particularly including, inter alia, community uses and supporting the evening economy.

Therefore, the PCCWM objects to the lack of appropriate wording within Policy SCE1 to address the expansion of the leisure evening economy which will impact on policing. It would be unsound for the impact of this significant area of growth and development to be ignored as it could potentially undermine the Plan’s Strategic Objectives and the sustainable development objectives of the NPPF. Similarly, there is no reference to safety, crime or disorder in the justification to the policy.

Safety issues of particular relevance to the evening economy include for example:

- Access to and from the facilities e.g. nearby public transport network, access to taxis and private hire vehicles;
- Safe and reasonably priced parking facilities - well lit, accessible car parks where people feel



safe, with CCTV and good access control, meeting the standards set out in the Police Crime Prevention Initiatives Safer Parking Scheme - ParkMark - About The Scheme
- Well-run premises, with qualified/licenced door staff, who are able to deal with the conflict and problems associated with such premises, as well as presenting a welcoming ‘customer service’ approach to people visiting the city and the premises concerned;
- CCTV facilities within bars, clubs and restaurants;
- Hot food takeaways/ late-night refreshment houses are often the flashpoint for violence after the pubs and clubs close;
- Late night opening off-licenses and small retail stores (that sell alcohol) tend to be ‘honey pots’, i.e. areas where people linger for longer than they would normally do so and attract increased levels of anti-social behaviour;
- Position of ATM (‘hole in the wall’ and ‘stand-alone’). These are often situated in night-time economy areas. These become ‘crime-generators’ (intoxicated people using cash machines are vulnerable to becoming victims of crime).
- ATMs and ATM replenishments. ATMs are a common focus of ‘cash in transit’ robberies - where cash vans are attacked, either entering or leaving a bank with cash bags, or replenishing ATMs. Across the UK (and Midlands) there have been a number of physical attacks on ATMs, including the use of gas – see best-practice-for-physical-atm-security.pdf (link.co.uk); and
- Sheesha (Shisha/Hookah) Lounges and the potential impact on surrounding
communities. These are increasing in number, but they do not fall under alcohol licensing or other forms of regulation. Many of these lounges have outside areas where people can smoke together. These are often unsafe, crowded shelters or internal areas which may not comply with smoking regulations. The police have to use powers afforded to other agencies (e.g., Fire and Environmental Services) to restrict inappropriate developments, which could be dangerous to the service-users or cause conflict within the local community. Policy opportunities to manage premises would be welcomed.

The PCCWM therefore requests that Policy SCE1 be modified by the introduction of the following text at 6(d) shown in bold:

‘6. A land use approach will be adopted to encourage regeneration and to meet the challenges facing Sandwell's centres, particularly as little retail capacity has been identified to support additional floorspace, through supporting:

…d. a variety of facilities, appealing to a wide range of age and social groups, provided in such a way to ensure a safe, accessible and inclusive environment and any anti-social behaviour is discouraged, for example through management, improved lighting and CCTV coverage where appropriate.’

Policy SCE2 - Non-E Class Uses in Town Centres

The PCCWM objects to the lack of appropriate wording within Policy SCE2 to address the expansion



of the non-E class uses in town centres which will primarily relate to the leisure evening economy - as drafted the policy will impact on policing. It would be unsound for the impact of this significant area to be ignored as whilst the policy makes reference to such uses as public houses and live music venues, it does not provide details of how such applications will be assessed in the context of crime and disorder and therefore the policy could potentially undermine the Plan’s vision and objectives and the sustainable development objectives of the NPPF.

The PCCWM considers that the general objectives of evening specific issues for any decision-maker include ensuring a thriving, vibrant economy where people can feel safe, with reduced crime and a reduction in the fear of crime.

The PCCWM objects to the lack of any reference in Policy SCE2 to crime, fear of crime, disorder or anti-social behaviour as considerations for planning applications for non-E class uses in town centres. The PCCWM requests that the policy be modified by the introduction of the following text shown in bold:

‘5. In all areas of Town Centres, it is important that a variety of facilities, appealing to a wide range of age and social groups, are offered and that these are provided in such a way to ensure a safe, accessible and inclusive environment and any anti-social behaviour is discouraged, for example through management, improved lighting and CCTV coverage where appropriate.’

Policies SCE3, SCE4 and SCE5

In these policies which relate to Town, District and Local Centres, as well as Small-Scale Local Facilities not in Centres, there is no reference in the policies to crime, fear of crime, disorder or anti-social behaviour as considerations for planning applications as would be expected in light of the Council’s statutory duty and its objectives and vision in the draft Sandwell Local Plan, and therefore the PCCWM objects and requests that these policies all contain the following wording:

‘In locations where there are considered to be issues concerning community safety, crime, and disorder, advice will be sought from the police and other safety organisations before planning permission is granted for proposals.’

The justification to the policies should similarly reference this requirement.

Policy SWB2 - Development in West Bromwich

The PCCWM objects to this Policy as it does not cross reference other relevant policies of note, including those relating to town centres, therefore the Policy should cross reference policies such as Policy SCE1 ‘Sandwell Centres’ etc. For example, point 4 should reference an amended Policy SDS5.



Policy SDM9 - Community Facilities

The PCCWM’s response to Policy SDS5 is also applicable to Policy SDM9, in terms of the importance of proposals relating to new community facilities needing to consider the threat of terrorism and measures to minimise crime and anti-social behaviour which can be associated with large gatherings. Policy SDM9 gives examples of the community facilities it applies to, which include but are not limited to, banqueting suites and entertainment venues, places of worship and / or religious instruction and community centres. However, such community uses have the potential to attract large numbers of people. Whilst the policy acknowledges that most community facilities would be best located in town centre, it is recognised that such uses also take place outside of town centres, therefore the policy references to uses attracting the congregation of large numbers of people should also be included in policies relating to sites outside of town centres.

Whilst Policy SDM9 makes reference to the need to consider noise and car parking in relation to such proposals, the policy makes no reference to the need for applicants to undertake an assessment as part of the design of new developments likely to attract large numbers of people, or to demonstrate and document how potential security and crime-related vulnerabilities have been identified, assessed and where necessary, addressed in a manner that is appropriate and proportionate.

The requirement for this is set out in the PCCWM response under Policy SDS5 above and the PCCWM objects to the omission of this policy wording under Policy SDM9, and requests a new bullet point that states that:

‘6. An assessment should be undertaken (as part of the design of new community developments likely to attract large numbers of people) to demonstrate and document how potential security and crime-related vulnerabilities have been identified, assessed and where necessary, addressed in a manner that is appropriate and proportionate.’

In addition, it is noted that the listed community facilities do not include emergency services such as police or fire, all of which are community facilities necessary for achieving sustainable development.

Policy ENV7 – Canals

The PCCWM objects to the omission of reference to the need to consider crime, anti-social behaviour, and the fear of crime when considering development proposals on the canal network. The policy justification acknowledges that ‘The network has significant value for nature conservation, tourism, health and wellbeing and recreation, and the potential to make an important contribution to economic regeneration through the provision of high-quality environments for new developments and a network of pedestrian, cycle and water transport routes.’ The success of the policy will to some extent be dependent upon people being and feeling



safe. It is therefore proposed that the following additional wording (shown in bold) be added as a modification to the policy:

‘3) Where opportunities exist, all development proposals within the canal network must:…

d. relate positively to the adjacent waterway by promoting high quality design, incorporating crime prevention measures by reference to Secured by Design principles to reduce crime, the fear of crime and anti-social behaviour, including active frontages onto the canal and improving the public realm;

g. include a management plan where appropriate to, for example, ensure any planting does not
provide concealment or facilitate illegal access to property or premises.’

Policy SDM1 – Design Quality

In accordance with national policy, it should be recognised that good design can have a role in reducing opportunities for crime and policies or design codes/ SPD should include reference to the mechanisms for achieving safe environments.

The PCCWM supports the proposed policy requirement (2d) that Design and Access Statements must demonstrate that a number of aspects of design have been addressed, including, ‘…d) crime prevention measures, Secured by Design and Park Mark principles and the requirements of Part Q of the Building Regulations 2010 or any successor legislation;’ However, the PCCWM considers the policy does not go far enough as it does not have a requirement for Secured by Design principles and Park Mark to be incorporated into development proposals. Furthermore, only some mainly larger planning applications require Design and Access Statements so as an overarching design policy for the plan, it should apply to all development proposals.

The PCCWM also supports the inclusion in point 4 of the policy that states that development must not cause an adverse impact on the living environment of occupiers of existing residential properties, or unacceptable living conditions for future occupiers of new residential properties, including in terms of ‘h) crime and safety’.

The PCCWM also supports the wording of justification paragraph 15.17 which explains that ‘A key objective for new developments should be that they create safe and accessible environments where crime, the fear of crime and anti-social behaviour do not undermine the quality of life, health or community cohesion. Good design, layout and spatial relationships (including the use of sensitively designed and located landscaping that reduces opportunities for anti-social behaviours) can make a positive contribution towards improving community safety in an area. It is the intention of Sandwell Council to work with the police towards the reduction of crime and the fear of crime, and anti-social behaviour across Sandwell. This will be a material consideration in all planning proposals.’ However, as this policy is the overarching design policy in the draft Local Plan, the PCCWM requests that reference is also made within this paragraph 15.17, to the need for



developers, as well as the local authorities, to engage with the West Midlands Police Design Out Crime Officers (DOCO) at the pre-application as well as the planning application stage.

Policy SDM6 – Hot Food Takeaways

The PCCWM supports a prescriptive policy on Hot Food Takeaways as set out, noting that the justification to the policy acknowledges that such uses (compared to other retail uses) are more likely to have, inter alia, a detrimental impact on amenity and such harmful impacts tend to increase anti-social behaviour.

However, it is considered that Policies SDM6 and SDM7 should be amalgamated into one policy as the inference is that if a proposal complies with the prescriptive and numerical thresholds under Policy SDM6 it will be acceptable, even though it at may not meet the criteria set out in Policy SDM7 – Management of Hot Food Takeaways – and vice versa. The PCCWM considers the criteria in Policy SDM7 to be equally important in the consideration of a planning application for a hot food takeaway, particularly as hot food takeaways are often a flashpoint for violence after pubs and clubs close.

Policy SDM7 – Management of Hot Food Takeaways

The PCCWM notes that the Council confirm at paragraph 15.62 that in addition to Policy SDM6,
‘…Policy SDM7 offers guidance on the requirements for the provision of hot food takeaways. Applicants wishing to provide or alter a hot food takeaway outlet should ensure they address the issues raised in the policy, which is designed to manage adverse impacts on adjacent residents and properties.’

However, it is noted that Policy SDM7 itself does not include any policy requirements to reflect the references in paragraphs 15.66 and 15.67 to such uses attracting gatherings of people and becoming a focus for anti-social behaviour and nuisance, especially at night. Paragraph 15.67 notes that where there are concerns in this respect, the applicant may be asked to contribute towards or install safety and security measures, such as CCTV systems.

In order for this consideration to carry appropriate weight, to reflect the reference to possible nuisance and anti-social behaviour created by hot food takeaways, the PCCWM objects to Policy SDM7 and requests that it should be amended to include a new point 8 (current point 8 should be renumbered 9) as follows –

‘Management of Associated Impacts…
8. In locations where there are considered to be issues concerning community safety, crime, and disorder, advice will be sought from the police and other safety organisations before permission is granted for proposals for new hot food takeaways.’



In accordance with the PCCWM comments made under Policy SDM6, it is considered that Policies SDM6 and SDM7 should be amalgamated into one policy as the inference is that if a proposal complies with the prescriptive and numerical thresholds under Policy SDM6 it will be acceptable, even though it at may not meet the criteria set out in Policy SDM7 – Management of Hot Food Takeaways – and vice versa.

Chapter 12 - Infrastructure and Delivery and Policies SID1 – SID3

Background to S106/CIL contributions towards Police infrastructure

The scale of the development during the plan period will inevitably have implications for the maintenance of safety and security in the Borough and there will clearly be a need for additional and/or enhanced Police infrastructure.

Policy SDS1 ‘Development Strategy’ which provides the overarching spatial strategy for Sandwell, sets out the scale and distribution of new development for the Plan period to 2041. The policy is clear that at point (1) ‘To support the attainment of the Sandwell SLP Vision, drive sustainable and strategic economic and housing growth and meet local aspirations, Sandwell, working with local communities, partners and key stakeholders, will make sure that decisions on planning proposals (c) ensure that sufficient physical, social, and environmental infrastructure is delivered to meet identified requirements’.

This is compatible with legislation and national planning policy, as follows:

Section 17 of the Crime and Disorder Act 1998 states, ‘Without prejudice to any other obligation imposed on it, it shall be the duty of each authority to which this section applies to exercise its various functions with due regard to the likely effect of the exercise of those functions on, and the need to do all that it reasonably can to prevent, crime and disorder in its area’. The PCCWM therefore has a statutory duty to secure the maintenance of an efficient and effective police force for the area. Sandwell Council is also statutorily required to consider crime and disorder and community safety in the exercise of its duties with the aim of achieving a reduction in crime.

The NPPF, September 2023, Paragraph 2 states that the NPPF must be taken into account in preparing the development plan and is a material consideration in planning decisions. Planning policies and decisions must also reflect relevant international obligations and statutory requirements.

Paragraph 7 of the NPPF explains that the purpose of the planning system is to contribute to the achievement of sustainable development and Paragraph 8 confirms that achieving sustainable development means that the planning system has three overarching objectives: an economic, a social and an environmental objective. These objectives include supporting strong, vibrant and healthy communities by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well-designed and safe



built environment.

Paragraph 20 of the NPPF includes, inter alia, a requirement for policies to deliver sufficient provision for infrastructure, including those related to security, with paragraphs 16, 26 and 28 indicating that this could be delivered through joint working with all partners concerned with new development proposals.

Section 8 of the NPPF ‘Promoting health and safe communities’, Paragraph 92, identifies that planning policies and decisions should aim to achieve healthy, inclusive and safe places which are safe and accessible, so that crime and disorder and the fear of crime, do not undermine the quality of life or community cohesion.

Paragraph 130 (f) of the NPPF calls for the creation of safe places where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

Annex 2 (NPPF) identifies the police as ‘Essential local workers’, defined as ‘Public sector employees who provide frontline services including health, education and community safety’.

It is also especially noteworthy that Part 10A Infrastructure Levy: England of the Levelling Up and Regeneration Act 2023 confirms at Section 204N (3) relating to Infrastructure Levy regulations that ‘infrastructure’ includes ‘(h) facilities and equipment for emergency and rescue services.

It should also be noted that it is the case that increases in local population and the number of households do not directly lead to an increase in funding for WMP from Central Government. It is therefore necessary to secure CIL and/or S.106 contributions for infrastructure due to the direct link between the increased demand for police services and changes in the physical environment due to new housing and economic growth, which have permanent impacts on future policing and demands upon WMP. Securing contributions towards policing enables the same level of service to be provided to residents of new developments, without compromising the existing level of service for existing communities and frontline services. Put simply, the consequence of no additional funding is that existing infrastructure will become severely stretched and thereby have a severe adverse impact on the quality of the service that WMP are able to deliver.

The High Court judgement of Mr Justice Foskett in The Queen and Blaby DC and Others [2014] EWHC 1719 (Admin) at Appendix 1 is a clear example of the case for S106/CIL contributions towards Police infrastructure. In that case, a development of 4,250 dwellings, community and retail development, schools and leisure facilities was proposed, the judgement reads:

‘It is obvious that a development of the nature described would place additional and increased burdens on local health, education and other services including the police force.’ (Para 11).



The judgement goes on to comment that:

‘Those who, in due course, purchase properties on this development, who bring up children there and who wish to go about their daily life in a safe environment, will want to know that the police service can operate efficiently and effectively in the area. That would plainly be the “consumer view” of the issue.’ (Para 61).

‘I am inclined to the view that if a survey of local opinion was taken, concerns would be expressed if it were thought that the developers were not going to provide the police with a sufficient contribution to its funding requirements to meet the demands of policing the new area.’ (Para 62).

To ensure that levels of service can be maintained for both existing and future residents in the wider Sandwell Borough area, developer contributions through the mechanism of CIL and/or
S.106 Obligations for Police infrastructure are considered essential.

It is the case that, Planning and S78 Appeal decisions (Appendix 2) have long recognised that the infrastructure requirements of the Police are perfectly eligible for consideration and can be allocated financial contributions through S106 Obligations which accompany qualifying planning permissions for major development (residential and commercial alike), with the Planning Inspector in PINS appeal reference APP/X2410/A12/2173673) stating that:

‘Adequate policing is so fundamental to the concept of sustainable communities that I can see no reason, in principle, why it should be excluded from purview of S106 financial contributions…’

Specific comments on Chapter 12 and policies SID1 – SID3

The PCCWM objects to the lack of reference in Chapter 12 and policies SID1 – SID3 to the requirement for Police infrastructure to serve the new development proposed in the draft Sandwell Local Plan. Chapter 12 of the Local Plan ‘Infrastructure and Delivery’ acknowledges at paragraph 12.1 that ‘Ensuring effective delivery of this amount of development [11,167 new houses and provide for 1,206ha of employment land] will require strong collaborative working with public, private and third sector partners, involving a robust process of infrastructure planning and delivery’, however the policies in that chapter solely reference digital infrastructure and the chapter covers no other forms of infrastructure, despite the ‘Introduction’ to the chapter at paragraph 12.1 stating ‘A key role of the SLP is to plan for the growth required for a sustainable and prosperous Sandwell.’

To achieve sustainable development, as required by the NPPF and PPG, the necessary supporting infrastructure must be identified through proactive engagement between the Council and the infrastructure providers, including the WMP. Infrastructure needs and costs arising as a result of the proposed growth in the draft Sandwell Local Plan should be included in



the Infrastructure Delivery Plan (IDP) – and representations have already been made by the PCCWM in this regard - and Viability and Delivery Study and specific requirements should be clearly set out in the individual site allocation policies and/or accompanying masterplans, Area Action Plans (AAPs) or Supplementary Planning Documents (SPDs), to ensure that developers are aware of their obligations at the outset. In addition, as the primary document for planning decisions, the draft Sandwell Local Plan must also address the need for sustainable safe developments supported by essential infrastructure including Police infrastructure. There also needs to be wording in relevant policies to require this, to ensure that developers are aware of the importance attached to issues of crime and safety by Sandwell MBC, as well as the need to maintain an appropriate level of community infrastructure and Emergency Services infrastructure.

The definition and support for infrastructure should be explicitly set out in the draft Local Plan, to meet national and local policy objectives relating to safety and security, and it should be clearly set out that contributions will be required through CIL/ S.106 agreements to help fund the provision and maintenance of facilities and equipment for Police services, in order to sustain the level of growth proposed in the draft Local Plan.

There are numerous examples of adopted planning policies in Local Plans which have been found sound after examination, which specifically refer to police infrastructure provision and contributions.

At the time of the Police’s representations to the Draft Black Country Plan Consultation (Regulation 18), it was noted that there was inclusion in the Viability and Delivery Study of an indicative contribution of £43.00 per dwelling towards the funding gap in Police infrastructure from the need for additional services arising directly from the proposed scale of growth. This was welcomed and the need for financial contributions in the form of CIL/S106 needs to be taken forward into policy, as well as the contribution figure needing to be increased/ linked to inflation.

Harm will result if West Midlands Police do not have the necessary funding to maintain an appropriate level of service for existing and for future residents, work and visitors within Sandwell (and surrounding areas) and therefore it is imperative that the draft Sandwell Local Plan addresses the need for sustainable safe developments supported by essential infrastructure.

Notwithstanding the clear omissions in these policies, there appears to be only limited reference to the emerging Infrastructure Delivery Plan in the draft Local Plan, it is only referenced 4 times and only in the justifications to Policy SDS3 – Towns and Local Areas, Policy SHW2 – Healthcare Infrastructure and Policy STR4– The Efficient Movement of Freight and Logistics. Most surprisingly, there is no reference to it whatsoever in Chapter 12 ‘Infrastructure and Delivery’ which is a great concern. The IDP should be regarded as integral to the local plan process with a commitment given to ensuring that it is maintained as a ‘live document’ throughout the plan



period.

As with many publicly funded services, Police forces within England have seen significant reductions in resources since 2010 due to reduced budgets. During this period, WMP has seen real terms funding reductions of in excess around 22% before taking into account the police officer uplift programme. As a result, the PCCWM has adopted a continuing programme of budgetary reductions, which in turn has had implications for operational pressures, against a backdrop of continued development (and in particular housing) growth within the WMP Force area.

Changes in general population do not increase the overall funding made available to WMP through Central Government grant. Even if there were to be an increase in funding because of development growth, such funding would be fully utilised in contributing to additional salary, revenue and maintenance costs (i.e. not capital costs). That being the case, such funding would not be available to fund the infrastructure costs that are essential to support significant new development growth during the Plan Period.

Full details of Police funding requirements are set out in the previous PCCWM representations, as reported in the Sandwell Infrastructure Delivery Plan Part 1: Infrastructure Needs Assessment, November 2023.

In order to meet the national policy objectives of ensuring safety, reducing crime and the fear of crime, it is vital that the Police are not under-resourced or deprived of legitimate sources of funding. The aim is to deploy additional staffing and additional infrastructure to cover the demand from new development at the same level as the policing delivered to existing households. Hence, additional development would generate a requirement for additional staff and additional personal equipment (such as workstations, radios, protective clothing, uniforms and bespoke training), police vehicles of varying types and functions.

If additional policing infrastructure is not provided, future growth in Sandwell will seriously impact on the ability of the Police to provide a safe and appropriate level of service and to respond to the needs of the local community. That outcome would be contrary to national policy.

Without this, the PCCWM objects to Chapter 12 and polices SID1-3 of the draft Local Plan. As the statutory Development Plan, it is the purpose of the draft Sandwell Local Plan to confirm the types of infrastructure which will be required to provide sustainable development in the Borough during the plan period and a new policy should be drafted accordingly.



Policy SDM8 - Gambling Activities and Alternative Financial Services

The PCCWM supports Policy SDM8 and particularly Point 6 as follows –

‘6. In determining any planning application for all pay day loan shops, pawnbrokers, and gambling uses the Council will consider any issues concerning community safety, crime, and disorder and will, where necessary, seek advice from the police and other safety organisations.’

The PCCWM recommends that the justification to this policy be expanded to cover point 6.

Glossary – SBD and Park Mark definitions

The PCCWM requests that definitions be provided of the following which are referred to in the draft Sandwell Local Plan.

‘Secured by Design –

Secured by Design (SBD) is the official police security initiative that is owned by the UK Police Service with the specific aim to reduce crime and help people live more safely. The Police seeks to improve the physical security of buildings using products, such as doors, windows, locks and walling systems that meet SBD security requirements. In addition, the Police include proven crime prevention techniques and measures into the layout and landscaping of new developments, such as maximising natural surveillance and limiting excessive through movement.

Through SBD, the Police work closely with builders, developers, local authorities and registered housing associations to incorporate police crime prevention standards from initial concept and design through to construction and completion. West Midlands Police have specially trained Designing Out Crime Officers (DOCOs) who offer police designing out crime and Secured by Design advice free of charge.

Park Mark –

The Safer Parking Scheme is a national standard for UK car parks that have low crime and measures in place to ensure the safety of people and vehicles. Each car park undergoes a rigorous assessment by specially trained police assessors and a Park Mark is awarded to each car park that achieves the challenging standards.

A Park Mark is awarded to parking facilities that have met the requirements of a risk assessment conducted by the Police, meaning the operator has put in place measures that deter criminal activity and anti-social behaviour.’



Conclusions

The Police and Crime Commissioner for West Midlands has a statutory duty to secure the maintenance of an efficient and effective police force in its area and Sandwell MBC has a statutory duty to consider crime and disorder and community safety in the exercise of its planning functions.

The PCCWM encourages the Council in the draft Sandwell Local Plan to ensure that the theme of community safety and crime prevention is given greater prominence on the basis that improving community safety, reducing crime, fear of crime and anti-social behaviour are vitally important to the creation of sustainable communities.

In addition, as the scale of development during the plan period will inevitably have implications for the maintenance of safety and security in the Borough, there will clearly be a need for additional and/or enhanced Police infrastructure. To ensure that levels of service can be maintained for both existing and future residents in the wider Sandwell Borough area, developer contributions through the mechanism of CIL and/ or S.106 Obligations for Police infrastructure are considered essential.

Lastly, the PCCWM has put forward a number of sites for residential development towards meeting the unmet needs of the Borough in terms of housing land supply.

Thank you for inviting comments on the Draft Sandwell Local Plan Review: Stage 2. Overall, we support this plan with many of the proposals referenced, fully assisting with the West Midlands Combined Authority (WMCA) goals and aspirations to create a more prosperous and better connected West Midlands which is fairer, greener and healthier and those within the agreed Core Strategy of the new West Midlands statutory Local Transport Plan (WMLTP5), the draft Six Big Moves and work on the Area Strategies. We especially welcome the positive ambition for improving transport across Sandwell, which outlines new opportunities within the coming years, and its bold intent for improving the transport system.

This version of the Sandwell Local Plan has also addressed many of our issues highlighted in the Issues and Options stage, or in previous responses to the Black Country Plan and this is very welcomed.

Many of the transport proposals referenced will assist in delivering wider economic growth aspirations including providing over 185 hectares of employment land and 29,773 new homes by 2041 (but appreciating the shortfalls in meeting these figures) together with continuing to help reduce transport impacts on people and places including supporting decarbonisation. We would therefore like to continue this strong partnership working in delivering on both WMLTP5 outcomes and in shaping the transport elements contained within the Sandwell Local Plan.

This response by Transport for West Midlands (TfWM), who are the transport arm of the WMCA and the region’s Local Transport Authority, consists of comments on the general strategic direction of the Local Plan, as well as some specific technical comments on various modes including public transport services, smart and active travel and the Key Route Network (KRN).

These comments, which predominantly focus on chapter 11 Transport, are now outlined below, with a focus on the questions posed in the consultation. However, we have also provided comments on other chapters of the local plan, which have implications on our transport network including housing, employment and local centres.
Introduction Section

Paragraph 60 under the header “Sandwell’s Spatial Portrait” it refers to the Strategic Road Network. However, this does not acknowledge the Major Road Network or Key Route Network that operates within Sandwell.
When describing the road network across Sandwell, it should be noted that the WMCA have recently begun a review of the Key Route Network (KRN) and subject to approval, the following changes will be implemented and will affect Sandwell. These being:

• The removal of the B4171 Birmingham Road from its junction with A4100 Henderson Way (Rowley Regis) to its junction with A459 Castle Hill (Dudley)
• NEW KRN: Sandon Road from its junction with A4030 Bearwood Road (Smethwick) to its junction with A4040 Barnsley Road (Birmingham)

Capturing opportunities through our levelling up zones as part of the ground-breaking Deeper Devolution Deal should also be noted, especially for those across the wider Black Country.

Therefore, making sure the Sandwell Local Plan picks up on these changes would be welcomed.

11. Transport Chapter

TfWM strongly welcomes reference to the importance of regional transport links being made and how the borough may impact other areas. We must point out however, that our ‘West Midlands Local Transport Plan 5 Core Strategy: Reimagining Transport in the West Midlands’ has now been approved, and while other elements of the suite of Local Transport Plan 5 (WMLTP5) documents have yet to be approved including our Six Big Moves and Area Strategies, these should all be approved by the end of 2024. Once all elements of the WMLTP5 are endorsed by the WMCA Board, Movement for Growth will be superseded by the WM LTP5.

Additionally, as a general comment whilst decarbonisation is mentioned within the Climate Change chapter, a key objective of our WM LTP5 is to decarbonise our transport system. We would therefore strongly encourage greater consideration of decarbonisation throughout all of the transport-related policies and in particular, be mindful of the work WMCA is undertaking as part of Adept’s Live Lab 2 programme with the Centre of Excellence for the Decarbonisation of local Roads (CEDR).

Introduction section

In the introduction section of the transport chapter (11), there appears to be parts of the KRN missing from Figure 13. This may be due to the mapping layers used but we would like clarification that the KRN is correctly designated on Sandwell’s highway network.

Furthermore, on page 17, paragraph 34 (and last bullet point) should be changed to say “Wednesbury to Brierley Hill Metro Extension via Dudley – this will create a direct public transport route from Wednesbury to the Wolverhampton to Walsall Birmingham New St rail line at the Dudley Port interchange”.

Additionally, on page 23 (section 61) this should read “West Coast Main Line” and not West Coast Mainline as is currently the case.

Policy STR1 – Priorities for the Development of the Transport Network

We strongly welcome this policy and broadly agree with it. However, our comments on Sandwell’s issues and options document still stand, where we requested stronger acknowledgement to exploring road space re-allocation for active travel and public transport. Our assessment of the challenges being faced by the region suggests this will be difficult to realise unless there are conscious efforts to reduce overall car dependency.

We would further welcome the plan capturing our ‘15 minute neighbourhood’ concept, together with exploiting the opportunities at regional interchanges to ensure that people can access other services (e.g. health and leisure) by public transport, with this being our ‘45 minute region’ concept.

Paragraph 11.17 should also reference and fully reflect the new West Midlands LTP Core strategy. And likewise, paragraph 11.20 should reference the Bus Service Improvement Plan which outlines a number of positive bus measures being introduced over the next few years to increase patronage and deliver on modal share targets.

While several measures in this local plan are clearly moving in a positive direction towards achieving this ambition, only by continuing to work in partnership, in areas like local plans/transport plans, we can collaboratively be “bolder” in the actions we take to support and drive behaviour change and respond to those difficult challenges, which in turn will then deliver on shared local, regional and national ambitions using a range of transport, land use and wider public policy levers.

While we fully agree that the impacts of Covid 19 have had significant impacts on patronage levels and taking several years to recover, which is talked about in the opening paragraph for this policy, we would welcome some statistics on this and the tone to be framed in a more positive manner, to not diminish the importance of public transport and the opportunities which lie ahead for us. But appreciating that bus services have been particularly impacted by rising fuel and inflationary costs as well as driver shortages and threatening their operational costs and viability. But with continued funding through the transport levy, from our local authority partners we remain positive in delivering a strong public transport network.

Whilst we further appreciate indirect references to our KRN Action Plans, elements of these are now considered (in parts) outdated, and we would welcome a greater emphasis placed on good partnership working with TfWM to deliver on these elements.

We further welcome reference to Park and Ride facilities where appropriate, but noting TfWM should be involved in any conversations regarding any development work which explores new Park and Ride locations, to ensure they are strategically located, take advantage of the links between the SRN and KRN, and help to reduce the number of private vehicle journeys.

It would also be helpful to have reference to Strategic Road Network Designated Routes for Unplanned Events (DRUEs). These routes could be indicated within Figure 13 and referenced in paragraph 11.31.

Finally, we welcome reference to coaches and their role in providing affordable long-distance connectivity. However, there is no policy or action detailing the promotion of coaches which we feel should be included.

Policy STR2 – Safeguarding the Development of the Key Route Network (KRN)

This is a strong policy and we fully welcome this, together with continued partnership working to develop strategies for the KRN. The KRN is important for making journeys across our region and will we continue working closely with Sandwell to ensure that this network:

• Provides safer and reliable journey times to ensure a consistent customer experience.
• Reflects the ‘Sustainable Transport User Hierarchy’ (as referenced in our 6 Big Moves) and rebalancing the needs of people, place, and vehicles.
• Ensures the KRN is resilient to existing and future challenges, and adaptable to emerging innovations to capitalise on future opportunities.

In terms of public transport, we welcome the importance placed on this mode but we recommend the narrative be strengthened around journey numbers rather than trips, which TfWM can provide on request.

In paragraph 11.23 the RTCC is the Regional Transport Coordination Centre and not the Regional Transport Control Centre, so please alter this.

In paragraph 11.24 reference is further made of providing “fast” public transport. Whilst this was likely intended to suggest that public transport could compete with private transport in terms of journey time, we would not encourage the use of this word. The Regional Road Safety Partnership is working toward Vision Zero and a safe system approach and believes all road users have a responsibility to use the network safely, so more appropriate wording like “reliable”, “dependable” or “consistent” public transport is recommended.

Finally, in paragraph 11.27 it mentions collaboration of all four authorities in their role as LHAs in managing the network efficiently. Presumably this is referring to the four Black Country Authorities, but we would also welcome the importance of Sandwell working collaboratively with its neighbouring Local Highway Authorities such as Birmingham City Council and National Highways.

Policy STR3 – Managing Transport Impacts of New Development

It is welcoming to see a stronger stance being applied to achieving accessibility for new development and the joined-up approach this policy lends itself to, which in turn, will contribute to the reduction of private vehicle journeys and good built-in public transport and active travel alternatives for all new developments.

While still no direct reference is made to the ‘Triple Access System’ of accessibility which includes: physical mobility, digital connectivity, and land use planning nor reference to our Big Move 2: Accessible and Inclusive Places, we can see this policy pays consideration to helping provide enhanced accessibility whilst also addressing the negative impacts of mobility on people and places. Through the Black Country LTP Area Strategy, we will further hope together, be able to capture some of these elements.

Under this policy, we would also like to ensure that all new development includes safe active travel infrastructure that makes connections to wider cycling and walking networks, as well as providing sustainable access and infrastructure to Park and Ride sites.

Provision of secure cycle parking at new developments is also important with infrastructure being aligned to LTN1/20 and Manual for Streets 2 guidance. The justification section could also provide more details of the risk exposure to cyclists and pedestrians, especially where the KRN provides facilities for fast, high-volume traffic. Providing near miss data (especially at junctions or where collisions involve cyclists and pedestrians) as well as undertaking spatial analysis (which appreciates the top deciles of areas of deprivation) will further be important, as these account for over 50% of all Killed and Seriously Injured in the region, with a reasonable proportion occurring in Sandwell. This data will then help justify a policy for these issues and TfWM can support in obtaining this data insight.

Policy STR4 – The Efficient Movement of Freight and Logistics

We welcome our previous comments on freight and logistics now being incorporated under a separate policy in its own right. We therefore welcome this policy, and the role new technologies could play in delivering more efficient, and sustainable alternatives, together with the use of rail to fulfil the increase in freight / HGV journeys, alongside that of e-commerce vehicles.

Incorporating a policy which supports new infrastructure on existing railway land, to grow and improve the existing local rail network is welcoming but the policy should also ensure it safeguards new depots or stabling sidings which would then support additional, and longer trains.

There is omission however of policies for suitable HGV parking provision to cater for the area’s anticipated use, including as appropriate stop over provision, and amenity facilities to serve the needs of HGV drivers.

Under this policy, the safety of pedestrians should also be captured, as 68% of fatal and serious collisions are a result of heavy goods vehicles.

While in the justification section it promotes the use of e-cargo bikes, low emission vehicles and the use of micromobility to transport goods, emphasing this in the policies would further be welcomed, especially for last mile journeys.

Finally, under this policy we would suggest reemphasising the need for greater consideration being placed on time-based policy for freight vehicles using the KRN and other roads, so that there are fewer clashes between peak commuter traffic and freight movements.

Policy STR5 – Creating Coherent Networks for Cycling and Walking

This policy is strongly welcomed, but its justification should take note that our KRN represents a significant number of journeys being made and is inclusive of bike journeys. Our ambitions focus heavily on delivering a segregated cycle network that matches the KRN, either directly, or via parallel routes, to serve our region’s centres, and so it is promising to see the proposed cycle routes delivering on this ambition.

Exploring further where there could be opportunity for innovation in this space would also be welcomed such as side road zebra crossings, table junctions or shared streets, with policies promoting the trialing of these.

Policy STR6 – Influencing the Demand for Travel and Travel Choices

Again, we fully welcome many of these policies and are extremely supportive of those measures which prioritise sustainable and active travel options which help contribute to a more reliable performance along our KRN and local roads.

Adding a policy which focuses on the importance of the reallocation of road space and providing greater priority at junctions to sustainable transport users may be worth exploring under this section, to strengthen this policy concerning demand for travel.

Yet it should be noted for new Park and Ride sites (where these maybe explored), our Park and Ride Strategy states “we will give priority to key intercept locations, rather than local park and ride expansions”. In fact, we put measures in place to discourage people from making short car trips to those local station / stops and encourage people to walk, wheel or use public transport instead, and ensure any car parking is available for people only who are travelling from further afield with investment in sustainable modes of travel being the first priority. This approach is taken, as over two thirds of our current users are travelling 2 miles or less.

Based on this evidence and our own policies in this area, the policy relating to park and ride should be re-worded to say: “identifying appropriate intercept park and ride sites on current public transport routes to ease traffic flows into centres and surrounding areas” and we should not be expanding local park and ride sites in already busy local, residential areas.

The policy could also be elaborated further concerning the need for more appropriate traffic calming measures and modal filters along residential roads. This would improve road safety and discourage cut-through driving.

The work undertaken by TfWM’s Behaviour Change Hub could also be touched upon through providing key travel planning information, advice and travel clinics as well as support where there is disruption.
Policy STR7 – Network Management

We are supportive of this policy and are happy to support Sandwell MBC in this duty through the sharing of TfWM assets and resources, as well as exploring innovative approaches together.

Policy STR8 – Parking Management
While many of these policies on parking management are strongly welcomed, there are no policies which promote parking provision for alternatives to car ownership, such as the use of zero emission vehicles (ZEV) car clubs or car sharing as examples.

Parking issues are also not specific to town centre car parks but are issues along key corridors such as the KRN. Therefore, parking should be seen as a bigger concern, beyond just town centres.

Within our LTP Core Strategy, we promote the managing of car parking more carefully (both in terms of availability and price). While we appreciate removing car parks all together and using the land for other uses, or raising car parking prices can often be contentious at first, they will often encourage more people to use public transport in the longer term. Where many places have undertaken these policies and raised revenue for reinvestment in more sustainable modes of travel, more positive results for both high streets and the wider locality have been achieved so we feel this policy could be strengthened much further.

There is further nothing relating to the enforcement of pavement parking laws to give that space back to people walking or wheeling or better enforcement of parking, moving traffic offences and Traffic Regulation Orders together with the digitisation of these to make them more accessible to the wider public or to enable more efficient loading and deliveries, noting proposals in the government’s Plan for Drivers documentation. This should also coincide with a simplification of on-street waiting and loading restrictions across Sandwell – and an agreed alignment across the West Midlands – to ensure drivers are not confused. This will help make enforcement easier and ensure greater compliance from road-users, ensuring there are fewer disruptions on our road networks caused from indiscriminate parking. If the policy section could capture these additions, we feel this could make a significant difference.

Finally considering a workplace parking levy to encourage more people to leave their cars at home when they commute could also be something the local plan explores.

Policy STR9 – Planning for Low Emission Vehicles

While we welcome the suggested policies proposed under this section including accommodating Zero Emission Vehicle (ZEV) charging networks, more fundamental shifts in behaviours, including a reduction in car usage will also be required. It should be further noted that ZEVs tend to be larger and heavier and produce higher levels of PM2.5 than conventional cars and many models require more space for parking, and therefore we should not seek to incentivise individuals to use an ZEV, over public transport and active travel modes.

It will also be important these policies align to WMCAs (Draft) ZEV Charging and Refueling Strategy, where Sandwell Council was a key partner in its development. This includes ensuring the location of EV charging points are strategically located.

Finally, TfWM would like to note that EV chargers can often be seen as part of the ever growing “street furniture clutter”. Therefore, with the importance of road space reallocation, priority should always be given to active travel and rapid transit before accommodating EV charging on the KRN and local road networks.

Policy STR10 – Transport Innovation and Digital Connectivity
The comments regarding how traffic signals can respond to levels of congestion and prioritise sustainable transport modes is supported. Yet at the same time, we would welcome further information that discusses the proven benefit of this at M5 J1 and how getting signals on UTC allows greater direct influence from signal engineers to support the network at times of need, via integration with Sandwell UTC and greater coordination with the RTCC.


Other transport related comments
In terms of traffic modelling, the growth estimated from the data TfWM have received in the uncertainty log for our models from local authorities (the log which records housing and employment developments) is considerably different from that of national forecasts. This was first an issue based on the WBHE business case work, and while we have developed an approach to deal with this, we believe we need to re-look at this in the new year. The Black Country Authorities including Sandwell are aware of these issues and it will be important to continue working closely with TfWM’s Transport Planning Team (with this function now being brought in-house). Especially in terms of the certainty of development so we can better control the process and requirements and fully align our transport schemes with those of new development coming forward.
Other chapter comments

3. Development Strategy
Policy SDS1 – Development Strategy

Under this policy header, the plan expresses a need to ensure growth is sustainable by allocating housing in locations with the highest levels of sustainable transport access to residential services (retail provision, schools, healthcare facilities, fresh food, employment etc).

Whilst fully supporting this, we feel this could be even stronger in that it should seek to ensure that all new development is designed to encourage sustainable travel and that it doesn't make transport worse in any way.


6. Health and Wellbeing in Sandwell
Policy SHW3 – Air Quality

While TfWM fully welcomes air quality being captured in this chapter, we would welcome embedding policies relating to air quality in all of the transport-related policies as well, due to the high percentage of responsibility that transport holds for air pollutants and policies throughout the local plan which favour growth in places which support sustainable modes and reduces the need to travel.

Also, whilst climate adaptation and ensuring the transport system is responding to climate impacts is picked up in chapter 15: Development Management, we need to ensure we reduce our carbon footprint and climate adaption is focused upon concerning transport in more detail, and not linked only to design but captured more generally.

7. Sandwell Housing
Policy SH03 - Housing Density, Type and Accessibility

Within the bullet points (for section 3 of the policy) we strongly feel a minimum of 50 dwellings per hectare and not 45 is recommended as a minimum. In many other local plans across England, 50 – 60 is often applied.

The local plan may also want to consider higher minimum housing densities for areas located along or close to high frequency public transport corridors or near to transport hubs.

Additionally, developing a public transport accessibility criteria for residential developments – depending on their location to high frequency transport corridors, stations and centres may further be of value in the local plan. We are aware of Greater Manchester Combined Authorities Places for Everyone Plan which maximises the number of people living in the most accessible places, helping to increase the proportion of trips made by walking, cycling and public transport, and reducing the demand for car-based travel.

Setting standards therefore to deliver on density appropriate developments at certain locations which reflect the relative accessibility of the site by walking, cycling and public transport and the need to achieve efficient use of land may add value to this local plan. And TfWM would therefore be happy to work with Sandwell MBC on this additional policy, if they feel it is appropriate.

8. Sandwell’s Economy
While we have no specific policies we would change in this section, we strongly welcome policy SEC5, in terms of access to labour markets. Yet accessibility could also be captured in the Strategic Employment Areas policies and Local Employment Areas, given that Sandwell has higher levels of non-car ownership than the rest of the West Midlands, so we need to ensure that all new employment is accessible by sustainable and active travel modes, for as many people to access as possible.

9. Sandwell’s Centres
Policy SCE1 - Sandwell's Centres
Similar to our comments concerning residential developments, in the general policy for centres across Sandwell, public transport accessibility to differing tiered centres could further be considered, with a criteria in place to ensure that they are well served, by the core bus network. Similar public transport accessibility criteria’s have been developed for other local plans – ensuring varying hierarchies of centres are serves by appropriate public transport provision and could be something Sandwell Council may want to consider developing within its local plan.

Conclusion

Overall, we very much welcome the sustainable transport ambitions set out in Sandwell’s Local Plan for improved connectivity via public transport and active travel infrastructure and we can clearly see many measures in this local plan moving in a positive direction to achieve our WM LTP5 ambitions.

Clearly many of our comments from the last version of the local plan have been included and we hope our above policy suggestions and comments, may further help strengthen the plan, and we welcome these being included in the final stage of the local plan. Our work with you on the Area Strategy for the Black Country will further help to improve the relationship between the Sandwell Local Plan and the development and delivery of transport strategy across Sandwell - be it concerning those key regional transport schemes like rapid transit and our core bus networks or in ways to support more local behaviour change and those measures that can help people move around more sustainably in their local neighbourhoods.

Introduction Section

Paragraph 60 under the header “Sandwell’s Spatial Portrait” it refers to the Strategic Road Network. However, this does not acknowledge the Major Road Network or Key Route Network that operates within Sandwell.

When describing the road network across Sandwell, it should be noted that the WMCA have recently begun a review of the Key Route Network (KRN) and subject to approval, the following changes will be implemented and will affect Sandwell. These being:

• The removal of the B4171 Birmingham Road from its junction with A4100 Henderson Way (Rowley Regis) to its junction with A459 Castle Hill (Dudley)
• NEW KRN: Sandon Road from its junction with A4030 Bearwood Road (Smethwick) to its junction with A4040 Barnsley Road (Birmingham)

Capturing opportunities through our levelling up zones as part of the ground-breaking Deeper Devolution Deal should also be noted, especially for those across the wider Black Country.

Therefore, making sure the Sandwell Local Plan picks up on these changes would be welcomed.

11. Transport Chapter
TfWM strongly welcomes reference to the importance of regional transport links being made and how the borough may impact other areas. We must point out however, that our ‘West Midlands Local Transport Plan 5 Core Strategy: Reimagining Transport in the West Midlands’ has now been approved, and while other elements of the suite of Local Transport Plan 5 (WMLTP5) documents have yet to be approved including our Six Big Moves and Area Strategies, these should all be approved by the end of 2024. Once all elements of the WMLTP5 are endorsed by the WMCA Board, Movement for Growth will be superseded by the WM LTP5.
Additionally, as a general comment whilst decarbonisation is mentioned within the Climate Change chapter, a key objective of our WM LTP5 is to decarbonise our transport system. We would therefore strongly encourage greater consideration of decarbonisation throughout all of the transport-related policies and in particular, be mindful of the work WMCA is undertaking as part of Adept’s Live Lab 2 programme with the Centre of Excellence for the Decarbonisation of local Roads (CEDR).
Introduction section
In the introduction section of the transport chapter (11), there appears to be parts of the KRN missing from Figure 13. This may be due to the mapping layers used but we would like clarification that the KRN is correctly designated on Sandwell’s highway network.
Furthermore, on page 17, paragraph 34 (and last bullet point) should be changed to say “Wednesbury to Brierley Hill Metro Extension via Dudley – this will create a direct public

transport route from Wednesbury to the Wolverhampton to Walsall Birmingham New St rail line at the Dudley Port interchange”.

Additionally, on page 23 (section 61) this should read “West Coast Main Line” and not West Coast Mainline as is currently the case.
Policy STR1 – Priorities for the Development of the Transport Network
We strongly welcome this policy and broadly agree with it. However, our comments on Sandwell’s issues and options document still stand, where we requested stronger acknowledgement to exploring road space re-allocation for active travel and public transport. Our assessment of the challenges being faced by the region suggests this will be difficult to realise unless there are conscious efforts to reduce overall car dependency.

We would further welcome the plan capturing our ‘15 minute neighbourhood’ concept, together with exploiting the opportunities at regional interchanges to ensure that people can access other services (e.g. health and leisure) by public transport, with this being our ‘45 minute region’ concept.

Paragraph 11.17 should also reference and fully reflect the new West Midlands LTP Core strategy. And likewise, paragraph 11.20 should reference the Bus Service Improvement Plan which outlines a number of positive bus measures being introduced over the next few years to increase patronage and deliver on modal share targets.

While several measures in this local plan are clearly moving in a positive direction towards achieving this ambition, only by continuing to work in partnership, in areas like local plans/transport plans, we can collaboratively be “bolder” in the actions we take to support and drive behaviour change and respond to those difficult challenges, which in turn will then deliver on shared local, regional and national ambitions using a range of transport, land use and wider public policy levers.

While we fully agree that the impacts of Covid 19 have had significant impacts on patronage levels and taking several years to recover, which is talked about in the opening paragraph for this policy, we would welcome some statistics on this and the tone to be framed in a more positive manner, to not diminish the importance of public transport and the opportunities which lie ahead for us. But appreciating that bus services have been particularly impacted by rising fuel and inflationary costs as well as driver shortages and threatening their operational costs and viability. But with continued funding through the transport levy, from our local authority partners we remain positive in delivering a strong public transport network.

Whilst we further appreciate indirect references to our KRN Action Plans, elements of these are now considered (in parts) outdated, and we would welcome a greater emphasis placed on good partnership working with TfWM to deliver on these elements.

We further welcome reference to Park and Ride facilities where appropriate, but noting TfWM should be involved in any conversations regarding any development work which explores new Park and Ride locations, to ensure they are strategically located, take advantage of the links between the SRN and KRN, and help to reduce the number of private vehicle journeys.

It would also be helpful to have reference to Strategic Road Network Designated Routes for Unplanned Events (DRUEs). These routes could be indicated within Figure 13 and referenced in paragraph 11.31.

Finally, we welcome reference to coaches and their role in providing affordable long-distance connectivity. However, there is no policy or action detailing the promotion of coaches which we feel should be included.

Policy STR2 – Safeguarding the Development of the Key Route Network (KRN)

This is a strong policy and we fully welcome this, together with continued partnership working to develop strategies for the KRN. The KRN is important for making journeys across our region and will we continue working closely with Sandwell to ensure that this network:

• Provides safer and reliable journey times to ensure a consistent customer experience.
• Reflects the ‘Sustainable Transport User Hierarchy’ (as referenced in our 6 Big Moves) and rebalancing the needs of people, place, and vehicles.
• Ensures the KRN is resilient to existing and future challenges, and adaptable to emerging innovations to capitalise on future opportunities.

In terms of public transport, we welcome the importance placed on this mode but we recommend the narrative be strengthened around journey numbers rather than trips, which TfWM can provide on request.

In paragraph 11.23 the RTCC is the Regional Transport Coordination Centre and not the Regional Transport Control Centre, so please alter this.

In paragraph 11.24 reference is further made of providing “fast” public transport. Whilst this was likely intended to suggest that public transport could compete with private transport in terms of journey time, we would not encourage the use of this word. The Regional Road Safety Partnership is working toward Vision Zero and a safe system approach and believes all road users have a responsibility to use the network safely, so more appropriate wording like “reliable”, “dependable” or “consistent” public transport is recommended.

Finally, in paragraph 11.27 it mentions collaboration of all four authorities in their role as LHAs in managing the network efficiently. Presumably this is referring to the four Black Country Authorities, but we would also welcome the importance of Sandwell working collaboratively with its neighbouring Local Highway Authorities such as Birmingham City Council and National Highways.

Policy STR3 – Managing Transport Impacts of New Development

It is welcoming to see a stronger stance being applied to achieving accessibility for new development and the joined-up approach this policy lends itself to, which in turn, will contribute to the reduction of private vehicle journeys and good built-in public transport and active travel alternatives for all new developments.

While still no direct reference is made to the ‘Triple Access System’ of accessibility which includes: physical mobility, digital connectivity, and land use planning nor reference to our Big Move 2: Accessible and Inclusive Places, we can see this policy pays consideration to helping

provide enhanced accessibility whilst also addressing the negative impacts of mobility on people and places. Through the Black Country LTP Area Strategy, we will further hope together, be able to capture some of these elements.

Under this policy, we would also like to ensure that all new development includes safe active travel infrastructure that makes connections to wider cycling and walking networks, as well as providing sustainable access and infrastructure to Park and Ride sites.

Provision of secure cycle parking at new developments is also important with infrastructure being aligned to LTN1/20 and Manual for Streets 2 guidance. The justification section could also provide more details of the risk exposure to cyclists and pedestrians, especially where the KRN provides facilities for fast, high-volume traffic. Providing near miss data (especially at junctions or where collisions involve cyclists and pedestrians) as well as undertaking spatial analysis (which appreciates the top deciles of areas of deprivation) will further be important, as these account for over 50% of all Killed and Seriously Injured in the region, with a reasonable proportion occurring in Sandwell. This data will then help justify a policy for these issues and TfWM can support in obtaining this data insight.

Policy STR4 – The Efficient Movement of Freight and Logistics

We welcome our previous comments on freight and logistics now being incorporated under a separate policy in its own right. We therefore welcome this policy, and the role new technologies could play in delivering more efficient, and sustainable alternatives, together with the use of rail to fulfil the increase in freight / HGV journeys, alongside that of e-commerce vehicles.

Incorporating a policy which supports new infrastructure on existing railway land, to grow and improve the existing local rail network is welcoming but the policy should also ensure it safeguards new depots or stabling sidings which would then support additional, and longer trains.

There is omission however of policies for suitable HGV parking provision to cater for the area’s anticipated use, including as appropriate stop over provision, and amenity facilities to serve the needs of HGV drivers.

Under this policy, the safety of pedestrians should also be captured, as 68% of fatal and serious collisions are a result of heavy goods vehicles.

While in the justification section it promotes the use of e-cargo bikes, low emission vehicles and the use of micromobility to transport goods, emphasing this in the policies would further be welcomed, especially for last mile journeys.

Finally, under this policy we would suggest reemphasising the need for greater consideration being placed on time-based policy for freight vehicles using the KRN and other roads, so that there are fewer clashes between peak commuter traffic and freight movements.

Policy STR5 – Creating Coherent Networks for Cycling and Walking

This policy is strongly welcomed, but its justification should take note that our KRN represents a significant number of journeys being made and is inclusive of bike journeys. Our ambitions focus heavily on delivering a segregated cycle network that matches the KRN, either directly,

or via parallel routes, to serve our region’s centres, and so it is promising to see the proposed cycle routes delivering on this ambition.

Exploring further where there could be opportunity for innovation in this space would also be welcomed such as side road zebra crossings, table junctions or shared streets, with policies promoting the trialing of these.

Policy STR6 – Influencing the Demand for Travel and Travel Choices

Again, we fully welcome many of these policies and are extremely supportive of those measures which prioritise sustainable and active travel options which help contribute to a more reliable performance along our KRN and local roads.

Adding a policy which focuses on the importance of the reallocation of road space and providing greater priority at junctions to sustainable transport users may be worth exploring under this section, to strengthen this policy concerning demand for travel.

Yet it should be noted for new Park and Ride sites (where these maybe explored), our Park and Ride Strategy states “we will give priority to key intercept locations, rather than local park and ride expansions”. In fact, we put measures in place to discourage people from making short car trips to those local station / stops and encourage people to walk, wheel or use public transport instead, and ensure any car parking is available for people only who are travelling from further afield with investment in sustainable modes of travel being the first priority. This approach is taken, as over two thirds of our current users are travelling 2 miles or less.

Based on this evidence and our own policies in this area, the policy relating to park and ride should be re-worded to say: “identifying appropriate intercept park and ride sites on current public transport routes to ease traffic flows into centres and surrounding areas” and we should not be expanding local park and ride sites in already busy local, residential areas.

The policy could also be elaborated further concerning the need for more appropriate traffic calming measures and modal filters along residential roads. This would improve road safety and discourage cut-through driving.

The work undertaken by TfWM’s Behaviour Change Hub could also be touched upon through providing key travel planning information, advice and travel clinics as well as support where there is disruption.

Policy STR7 – Network Management

We are supportive of this policy and are happy to support Sandwell MBC in this duty through the sharing of TfWM assets and resources, as well as exploring innovative approaches together.

Policy STR8 – Parking Management

While many of these policies on parking management are strongly welcomed, there are no policies which promote parking provision for alternatives to car ownership, such as the use of zero emission vehicles (ZEV) car clubs or car sharing as examples.

Parking issues are also not specific to town centre car parks but are issues along key corridors such as the KRN. Therefore, parking should be seen as a bigger concern, beyond just town centres.

Within our LTP Core Strategy, we promote the managing of car parking more carefully (both in terms of availability and price). While we appreciate removing car parks all together and using the land for other uses, or raising car parking prices can often be contentious at first, they will often encourage more people to use public transport in the longer term. Where many places have undertaken these policies and raised revenue for reinvestment in more sustainable modes of travel, more positive results for both high streets and the wider locality have been achieved so we feel this policy could be strengthened much further.

There is further nothing relating to the enforcement of pavement parking laws to give that space back to people walking or wheeling or better enforcement of parking, moving traffic offences and Traffic Regulation Orders together with the digitisation of these to make them more accessible to the wider public or to enable more efficient loading and deliveries, noting proposals in the government’s Plan for Drivers documentation. This should also coincide with a simplification of on-street waiting and loading restrictions across Sandwell – and an agreed alignment across the West Midlands – to ensure drivers are not confused. This will help make enforcement easier and ensure greater compliance from road-users, ensuring there are fewer disruptions on our road networks caused from indiscriminate parking. If the policy section could capture these additions, we feel this could make a significant difference.

Finally considering a workplace parking levy to encourage more people to leave their cars at home when they commute could also be something the local plan explores.

Policy STR9 – Planning for Low Emission Vehicles

While we welcome the suggested policies proposed under this section including accommodating Zero Emission Vehicle (ZEV) charging networks, more fundamental shifts in behaviours, including a reduction in car usage will also be required. It should be further noted that ZEVs tend to be larger and heavier and produce higher levels of PM2.5 than conventional cars and many models require more space for parking, and therefore we should not seek to incentivise individuals to use an ZEV, over public transport and active travel modes.
It will also be important these policies align to WMCAs (Draft) ZEV Charging and Refueling Strategy, where Sandwell Council was a key partner in its development. This includes ensuring the location of EV charging points are strategically located.
Finally, TfWM would like to note that EV chargers can often be seen as part of the ever growing “street furniture clutter”. Therefore, with the importance of road space reallocation, priority should always be given to active travel and rapid transit before accommodating EV charging on the KRN and local road networks.
Policy STR10 – Transport Innovation and Digital Connectivity
The comments regarding how traffic signals can respond to levels of congestion and prioritise sustainable transport modes is supported. Yet at the same time, we would welcome further information that discusses the proven benefit of this at M5 J1 and how getting signals on UTC allows greater direct influence from signal engineers to support the network at times of need, via integration with Sandwell UTC and greater coordination with the RTCC.

Other transport related comments
In terms of traffic modelling, the growth estimated from the data TfWM have received in the uncertainty log for our models from local authorities (the log which records housing and employment developments) is considerably different from that of national forecasts. This was first an issue based on the WBHE business case work, and while we have developed an approach to deal with this, we believe we need to re-look at this in the new year. The Black Country Authorities including Sandwell are aware of these issues and it will be important to continue working closely with TfWM’s Transport Planning Team (with this function now being brought in-house). Especially in terms of the certainty of development so we can better control the process and requirements and fully align our transport schemes with those of new development coming forward.

Other chapter comments

3. Development Strategy
Policy SDS1 – Development Strategy

Under this policy header, the plan expresses a need to ensure growth is sustainable by allocating housing in locations with the highest levels of sustainable transport access to residential services (retail provision, schools, healthcare facilities, fresh food, employment etc).

Whilst fully supporting this, we feel this could be even stronger in that it should seek to ensure that all new development is designed to encourage sustainable travel and that it doesn't make transport worse in any way.


6. Health and Wellbeing in Sandwell
Policy SHW3 – Air Quality

While TfWM fully welcomes air quality being captured in this chapter, we would welcome embedding policies relating to air quality in all of the transport-related policies as well, due to the high percentage of responsibility that transport holds for air pollutants and policies throughout the local plan which favour growth in places which support sustainable modes and reduces the need to travel.

Also, whilst climate adaptation and ensuring the transport system is responding to climate impacts is picked up in chapter 15: Development Management, we need to ensure we reduce our carbon footprint and climate adaption is focused upon concerning transport in more detail, and not linked only to design but captured more generally.

7. Sandwell Housing
Policy SH03 - Housing Density, Type and Accessibility

Within the bullet points (for section 3 of the policy) we strongly feel a minimum of 50 dwellings per hectare and not 45 is recommended as a minimum. In many other local plans across England, 50 – 60 is often applied.

The local plan may also want to consider higher minimum housing densities for areas located along or close to high frequency public transport corridors or near to transport hubs.

Additionally, developing a public transport accessibility criteria for residential developments – depending on their location to high frequency transport corridors, stations and centres may further be of value in the local plan. We are aware of Greater Manchester Combined Authorities Places for Everyone Plan which maximises the number of people living in the most accessible places, helping to increase the proportion of trips made by walking, cycling and public transport, and reducing the demand for car-based travel.

Setting standards therefore to deliver on density appropriate developments at certain locations which reflect the relative accessibility of the site by walking, cycling and public transport and the need to achieve efficient use of land may add value to this local plan. And TfWM would therefore be happy to work with Sandwell MBC on this additional policy, if they feel it is appropriate.

8. Sandwell’s Economy
While we have no specific policies we would change in this section, we strongly welcome policy SEC5, in terms of access to labour markets. Yet accessibility could also be captured in the Strategic Employment Areas policies and Local Employment Areas, given that Sandwell has higher levels of non-car ownership than the rest of the West Midlands, so we need to ensure that all new employment is accessible by sustainable and active travel modes, for as many people to access as possible.

9. Sandwell’s Centres
Policy SCE1 - Sandwell's Centres

Similar to our comments concerning residential developments, in the general policy for centres across Sandwell, public transport accessibility to differing tiered centres could further be considered, with a criteria in place to ensure that they are well served, by the core bus network. Similar public transport accessibility criteria’s have been developed for other local plans – ensuring varying hierarchies of centres are serves by appropriate public transport provision and could be something Sandwell Council may want to consider developing within its local plan.

Conclusion

Overall, we very much welcome the sustainable transport ambitions set out in Sandwell’s Local Plan for improved connectivity via public transport and active travel infrastructure and

we can clearly see many measures in this local plan moving in a positive direction to achieve our WM LTP5 ambitions.
Clearly many of our comments from the last version of the local plan have been included and we hope our above policy suggestions and comments, may further help strengthen the plan, and we welcome these being included in the final stage of the local plan. Our work with you on the Area Strategy for the Black Country will further help to improve the relationship between the Sandwell Local Plan and the development and delivery of transport strategy across Sandwell - be it concerning those key regional transport schemes like rapid transit and our core bus networks or in ways to support more local behaviour change and those measures that can help people move around more sustainably in their local neighbourhoods.

Comments submitted in table form
Para 72 Consider re-phrasing and celebrating the industrial heritage of the area and how that has shaped the local identity of the area.
Para 73 Amend to ‘Registered Parks and Gardens’.
Consider amending heritage conservation areas to conservation areas and the setting of heritage assets or something similar.
Heritage assets themselves are ‘irreplaceable’ and should be conserved and protected and the Local Plan to provide a ‘positive strategy’ for this.
Their need to be protected is more than a recognition of their past use but as how heritage has shaped our identity and how they continue to remain relevant today and can contribute positively to the economy and social wellbeing.

It would be useful in this section if heritage can also be referenced as a component of landscape.
Page 29 Ambition 1 would benefit from a reference to the historic environment and recognising the benefits the historic environment can bring to a community and an area.

Ambition 2 would benefit from a reference to the historic environment and recognising the benefits the historic environment can bring to a community and wellbeing.

Would be worthwhile to check through the ambitions to consider where the historic environment would best be suited.


Page 33/34 We support the vision and the reference to heritage within it. We would welcome a reference to a wider variety of heritage such as heritage landscape/ archaeology etc. rather than a narrower definition of built heritage.
Objective 4/5 We are very supportive of specific objectives that seek to protect the historic environment. We would welcome a reference to heritage landscape and features and ensuring the wide range of historic environment is fully reflected and considered within the Plan.
Objective 15 We support the reference to heritage within this objective.
Para 2.18 We support this paragraph.
Para 2.30 clause C We support this clause.
Policy SDS1 clause j This could be amended to read conserve and enhance the significance of the historic environment, heritage assets and their settings through xxx to ensure that it is the significance of heritage assets that is being considered and protected through the policy text.
Policy SDS2 This policy would benefit from reference to the historic nature of the area and its heritage assets and how conserving the historic environment will be a benefit for the regeneration of the area. It would also be useful to reference the Wednesbury High Street Action Zone during the text regarding regeneration in Sandwell and the benefit of heritage led regeneration programmes. This would help meet the aims of the Plan mentioned earlier in the text. We note a brief reference in paragraph 3.42.
Policy SDS3 clause a) i)

d) We would request re-phrasing of this clause as sites submitted during a Call for Sites exercise will not necessarily be suitable for development. We would request that this is also re-phrased in any other policies that this statement may appear.

Could make reference to the historic environment.
Policy SDS4
Clause 2)

Clause 3)


Clause 9)
We support this reference and recommend additional detail in the Plan on how this can be achieved.

Confusing wording, we would request that this is amended yet we support the principle that the significance of heritage assets including their setting will be protected and it would benefit from a clearer form of words. Also consider re-wording paragraph 3.61.

Historic England are available to engage in this work.
Policy SDS5 clause 11) We support the reference to heritage tourism and welcome its inclusion in the policy, as well as in the justification paragraphs.
Section on Green and Blue Infrastructure from page 74 onwards We would welcome a reference to the historic environment as a component of green and blue infrastructure and the role heritage plays in this area. If you have any questions we are happy to answer.
Policy SDS7 We would request a clause to be included in this policy regarding the historic environment and its function within Green/ Blue Infrastructure.
Policy SNE4 We welcome a policy on the UNESCO Geopark and recognition of the important cultural heritage of the area and the contribution it has made in historical terms. Clause 1) consider re-phrasing to ensure that the significance of the asset and its integrity is fully protected and conserved for future generations.
Policy SNE5 This policy would benefit from strengthening the reference to the historic environment context of the area, including non designated heritage assets and heritage features as well as the heritage components of landscape.

Policy SNE6 We support the recognition of the historic nature of canals as heritage assets/ role within the wider cultural heritage agenda and welcome reference within the policy and justification text in this area.

Section 4, from page 113
We welcome a specific section on the historic environment and specific policies for the historic environment. We welcome the introductory paragraphs to the interesting, rich and varied history of the Black Country and the need to protect this and the value placed on heritage led regeneration.

Para 4.114
Consider the wording in this paragraph and also needs reference to the setting of heritage assets as well as an understanding of the context in which they are in and any relationships they may have with other heritage assets within the area/ heritage landscapes etc.

When considering a suite of policies for the historic environment, it is important to ensure that all the policies are consistent and that all assets are fully supported.

SHE1
We welcome the inclusion of this policy. We would request that there are some amendments to the wording to ensure it is compliant with the National Planning Policy Framework (NPPF), paragraphs 199 to 205 particularly. Heritage assets are an ‘irreplaceable resource’ and efforts should be made to ensure that the significance of heritage assets, including their setting are protected. The policy wording in clause 1 and 2 can be strengthened to reflect this. The wording in clause 3 is welcome and we are supportive of the need for Heritage Impact Assessment. The assessment should also set out the level of harm, how harm can be avoided or mitigated against and any opportunities for enhancement. Clause 4, setting in itself is not a heritage asset but it should be included within the section on significance and can still be a reason for refusal where the setting contributes to the significance of an asset, but will be affected by proposed development. Recording the loss of any heritage asset/ features on the Historic Environment Record (HER) would also be beneficial to include within this policy. Consider the wording for clause 5 to ensure the protection of a Conservation Area. We would recommend deleting clause 6. Paragraph 4.121 relates to this paragraph also.

SHE2

Similar to comments above, ensure that the policy is NPPF compliant and that it seeks to protect and conserve the historic environment and sets out where applications will be refused. As referenced the historic environment is an ‘irreplaceable resource’ and the NPPF sets out clearly how to deal with harm and how if necessary to apply the tests of harm. Clause 1 for example requests that heritage informs proposals and is considered; there should be a clause that states that harm to heritage will be refused unless xx. Again, clause 2 refers to the need to inform proposals which is beneficial, yet there needs to be wording inserted to prevent harm to the historic environment and conserve their significance, including setting.

Where ‘historic assets’ are referenced this should be amended to state ‘heritage assets’.
Clause 3, heritage assets should be protected as set out in the NPPF and relevant legislation.

Clause 5, delete ‘aim’. The policy wording should be strengthened to ensure that heritage assets are protected and conserved in Sandwell. The examples used are useful and provide a context for the type of heritage within the Borough; it would be beneficial to ensure that this describes some examples only and reference the relevant heritage evidence base that prospective developers will need to consider in full.

It would be beneficial to have a clause that relates to the need for appropriate qualified individuals undertaking assessment work, that the Historic Environment Record should be considered as a minimum, that views analysis is a useful tool to consider in the wider process etc. for all proposals which could affect heritage.


Para 4.123
Delete ‘ancient’.

It would be useful to provide some additional information about what a heritage impact assessment could include.
SHE3
Consider referring to significance generally in this clause. It would be useful to have a link to the Sandwell Local List. We are supportive of a Local List and welcome this.

SHE4
Considering re-phrasing the opening clause to ensure that the significance of archaeological heritage assets are protected and where possible enhanced.

Development proposals which cause harm to heritage assets should be refused unless the specifications set out in the NPPF are met. We consider that the wording should reflect this. There also needs to be consideration of non designated archaeology that could be of national significance. Ensure that heritage assets are referred to in line with the relevant clauses of Section 16 of the NPPF. A separate clause for archaeological investigation would be useful and to set out how it applies to heritage assets. Any archaeological investigation should be carried out by an appropriate and qualified professional and a programme of works agreed by the Council’s archaeology officer. A separate clause for recording would be beneficial. Clause 5 we would anticipate that all relevant information would be provided for the Council to assess the level of harm and to then make an informed decision within the context of the requirements of the NPPF.

4.133/34
Additional information would be beneficial.
Consider re-ordering the policies to have a historic environment policy first, and then specific policies on asset type, where relevant.

Section 5 Historic England are supportive of a section on Climate Change within the Plan. We enclose a link to some relevant publications considering the historic environment and climate change that may be useful to understand in the context of the Local Plan.

https://historicengland.org.uk/advice/climate-change/

Under this section it would be useful to consider how the historic environment can contribute to the climate change agenda, which measures are appropriate in the context of the historic environment and how heritage assets need to be considered. There may also be times when climate change proposals such as solar farms or wind turbines may not be an appropriate solution if it affects the significance of heritage assets and other areas may be more suitable for this technology.

Policy SCC1 We welcome clause j). It could relate to heritage assets more widely.
Policy SCC2 Clause 4 is useful. It may need to be stated that development which causes harm will be resisted or other solutions sought.

Policy SCC3 Clause 2, consider the potential impacts for the historic nature of canals and ensure that this is protected and conserved.

Policy SCC4 It would be useful to incorporate a clause on the historic environment within this policy and the specific considerations for the historic environment.

Policy SCC5 It would be useful to incorporate a clause on the historic environment within this policy and the specific considerations for the historic environment.

Policy SCC6 We would recommend re-phrasing to state protects the significance of the historic environment, heritage assets including their setting or similar wording.

Policy SHW4 We support the reference to heritage within clause 8.

Policy SH01 We have not been able to comment on the specific housing proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SHO2 Clause 2) c amend to will not cause harm to the significance of heritage assets, including their setting or similar.
Policy SH010 We have not had the opportunity at this time to comment on the site allocations specifically. We would request that any proposed allocations consider the impact on the historic environment and ensure that where there is harm for the historic environment that an appropriate heritage impact assessment is available as an evidence base to support a proposed allocation.
Policy SEC1 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SEC2 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SEC3 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SCE1 This policy would benefit from a clause relating to the historic environment, heritage led regeneration, heritage led public realm improvements, information relating to shop fronts and design within heritage centres and conservation areas and reference to Wednesbury High Street Heritage Action Zone and other potential opportunities.
Para 9.161 Are there any proposals within the Plan to address this?
Para 9.283 onwards We welcome the inclusion of this section in the Plan. Are there any tools or opportunities from this project that could be replicated elsewhere in the Borough?
Policy SWB1 This policy would benefit from a clause on the historic environment.
Policy STR1 How has the historic environment been considered in the process of highlighting transport infrastructure needs? Have any assessments been undertaken about the potential for harm to heritage assets, as a result of proposed transport initiatives?
Policy STR2 Comments above apply.
Policy STR6 Is there any information available at present about potential park and ride sites?
Policy SWA1 We would recommend re-phrasing clause 3) f to ensure that the policy protects the significance of heritage assets including their setting and inappropriate waste developments will be resisted. The policy may further benefit from some additional text on this issue in the reasoned justification text.
Policy SWA3 We have not been able to comment on specific proposed waste sites at this time. We will assess these in the new year and would welcome a meeting with the Council to discuss proposed allocations and any impacts these may have on the historic environment. If any proposed allocations could impact on the historic environment, we would expect to see a heritage impact assessment as evidence base.
Policy SWA4 This policy would benefit from a clause on the historic environment.
Policy SMI1 Are there minerals sites that are being proposed for allocation or safeguarding? If so, how has the historic environment been considered in this process?
Policy SMI2 Clause 5) b should set out an approach for what happens if a mineral working site is not appropriate due to the harm to the historic environment or if there are mitigation measures required to overcome any harm. The clause for cumulative impacts could also apply for the historic environment where there are already approved mineral workings in a historic landscape.

The policy would benefit from a clause on remediation so that the long term future of any minerals working site is appropriate in its environment.

Para 13.012 This para would benefit from additional detail.

SDM1 Clause g) we welcome reference to the historic environment within this policy and would request that ‘historic assets’ are amended to ‘heritage assets’ and that the significance of heritage assets including their settings are protected and where possible, enhanced.

Policy SDM3 Does the Council have any evidence base relating to tall buildings and which has been/ could be used to inform locations which may be appropriate or may not be appropriate for tall buildings? We have concerns about the impact of this policy on the historic environment and the historic nature of the area and are keen to understand if there is more information available at this time that has considered these issues?

With reference to both tall buildings and gateway sites, we are unclear what has informed the policy and what the policy is seeking to achieve.

Policy SDM5 It would be useful to include a section on the historic environment and what is appropriate in the context of heritage assets including conservation areas and listed buildings.