All new developments should be implemented with basic Low Traffic Neighbourhood and 15 minute city principles - ie no through traffic and local amenities close by.

Permeability Across Motorways and Key Route Network:
We recommend a thorough consideration of permeability across the motorway and key route network for pedestrians and cyclists. Ensuring safe and convenient crossing points is crucial for promoting active travel and creating an integrated transport network.

Interactions of Multi-Modal Journeys:
The plan should emphasise the importance of seamless interactions between various modes of transportation. Integration between walking, cycling, and public transport is essential for creating a cohesive and user-friendly transport system.

Inclusion of National Cycle Network:

The draft plan lacks explicit mention of the National Cycle Network. We recommend its inclusion as a key element in the cycling chapter to highlight the importance of regional and national connectivity for cyclists.

Road Space Reallocation and Speed Management:

The plan is unclear on the need for road space reallocation or changes in speeds to prioritise active travel. We suggest that a default consideration of reallocating road space and managing speeds should be incorporated to promote active travel.

Inclusion and Diversity in Accessibility:

While accessibility is briefly mentioned, the plan should elaborate on inclusion and diversity, ensuring that design for active travel accommodates everyone, including those with diverse mobility needs.

Linking Developments to the Network:

The plan should emphasize how new developments will link to the existing network. Consideration should be given to creating secondary networks to fill gaps, ensuring a comprehensive and well-connected active travel infrastructure.

Car Parking Ratios in New Developments:

Given Sandwell's high ratio of car parking in new developments, we recommend exploring policies that support and incentivise active travel, potentially reevaluating parking requirements to encourage walking and cycling.

Car Parking on Kerbs as an Issue:

The plan should address concerns related to car parking on kerbs as it may impact the safety and convenience of pedestrians and cyclists. Policies should be developed to minimise such issues and promote a safer environment for active travel.

Public Transport Accessibility for All:
The plan should emphasise the importance of making public transport accessible to all, including individuals with disabilities. This involves not only physical accessibility but also ensuring that information and services are inclusive.

Promotion of Active Travel Initiatives:

We would encourage the inclusion of initiatives to actively promote walking and cycling, such as public awareness campaigns, community events, and educational programs to foster a culture of active transportation.

Community Engagement in Planning:
We advocate for meaningful community engagement in the planning process, ensuring that local residents and stakeholders have a say in the development of the transport network to address specific community needs and concerns.


In conclusion, we believe that addressing these points will contribute to the development of a transport network that prioritises sustainability, accessibility, and the well-being of the community. We appreciate your consideration of our comments and look forward to continued collaboration in fostering a transport system that aligns with the principles of active travel.

Permeability Across Motorways and Key Route Network:
We recommend a thorough consideration of permeability across the motorway and key route network for pedestrians and cyclists. Ensuring safe and convenient crossing points is crucial for promoting active travel and creating an integrated transport network.

Interactions of Multi-Modal Journeys:
The plan should emphasise the importance of seamless interactions between various modes of transportation. Integration between walking, cycling, and public transport is essential for creating a cohesive and user-friendly transport system.

Inclusion of National Cycle Network:

The draft plan lacks explicit mention of the National Cycle Network. We recommend its inclusion as a key element in the cycling chapter to highlight the importance of regional and national connectivity for cyclists.

Road Space Reallocation and Speed Management:

The plan is unclear on the need for road space reallocation or changes in speeds to prioritise active travel. We suggest that a default consideration of reallocating road space and managing speeds should be incorporated to promote active travel.

Inclusion and Diversity in Accessibility:

While accessibility is briefly mentioned, the plan should elaborate on inclusion and diversity, ensuring that design for active travel accommodates everyone, including those with diverse mobility needs.

Linking Developments to the Network:

The plan should emphasize how new developments will link to the existing network. Consideration should be given to creating secondary networks to fill gaps, ensuring a comprehensive and well-connected active travel infrastructure.

Car Parking Ratios in New Developments:

Given Sandwell's high ratio of car parking in new developments, we recommend exploring policies that support and incentivise active travel, potentially reevaluating parking requirements to encourage walking and cycling.

Car Parking on Kerbs as an Issue:

The plan should address concerns related to car parking on kerbs as it may impact the safety and convenience of pedestrians and cyclists. Policies should be developed to minimise such issues and promote a safer environment for active travel.

Public Transport Accessibility for All:
The plan should emphasise the importance of making public transport accessible to all, including individuals with disabilities. This involves not only physical accessibility but also ensuring that information and services are inclusive.

Promotion of Active Travel Initiatives:

We would encourage the inclusion of initiatives to actively promote walking and cycling, such as public awareness campaigns, community events, and educational programs to foster a culture of active transportation.

Community Engagement in Planning:
We advocate for meaningful community engagement in the planning process, ensuring that local residents and stakeholders have a say in the development of the transport network to address specific community needs and concerns.


In conclusion, we believe that addressing these points will contribute to the development of a transport network that prioritises sustainability, accessibility, and the well-being of the community. We appreciate your consideration of our comments and look forward to continued collaboration in fostering a transport system that aligns with the principles of active travel.

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.

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.

The draft Local Plan contains locally specific policies and strategic / non-strategic site allocations to support the housing and employment requirements across Sandwell for the plan period of 2022 to 2041. We note that when adopted, this Local Plan will

replace the Black Country Core Strategy (adopted in 2011), the Sandwell Site Allocations and Development Plan Document (the SAD, adopted in 2012) and Area Action Plans for West Bromwich, Smethwick and Tipton. We also note that the Local Plan will incorporate elements of former supplementary planning documents as appropriate and will include details from the West Bromwich Masterplan and Interim Planning Statement.

National Highways agree in principle to the vision and objectives of the Draft Local Plan.

Housing and employment requirements

Based on our review of the Regulation 18 consultation, we note that the housing and employment requirement has changed slightly since the ‘Issues and Options’ consultation. The draft Local Plan consultation document outlines that there is a requirement to deliver 185 hectares of employment land and 29,773 dwellings over the plan period up to 2041. We note that the housing and employment requirement have primarily been identified based on the National Standard method on housing projections and Economic Development Need Assessment (EDNA) respectively.

While the housing demand stands at 29,773 dwellings, supply for 11,167 dwellings is expected to come through the adoption of the upcoming Local Plan, thereby leaving an unmet need for 18,606 homes. We appreciate that the Council will liaise with the neighbouring authorities to help accommodate some of Sandwell’s unmet housing needs through their own housing provision. National Highways welcomes further information on this once the Council identifies the working arrangement and we look forward to understanding the impacts from these developments on the SRN in the area as you progress into Regulation 19.

The quantum of employment land intended to be delivered through the Local Plan is 42ha, with a shortfall of 143ha. We note that the housing and employment supply identified in the Draft Local Plan has considered the existing planning applications, sites under construction, and windfall allowance.

We note that a Sustainability Appraisal process has been undertaken to streamline the different housing and employment growth options and acknowledge that the allocation of sites has taken into consideration the location, availability of greenfield/ brownfield sites, and sustainability elements through a ‘Balanced Green Growth’ approach. We note that the new development allocations are focussed within the Regeneration Areas and Centres, which is likely to lead to a more efficient use of land and in improving the sustainable travel options.

Sustainable transport

We acknowledge that the Draft Local Plan has specifically focussed on policies to tackle climate change by reduction in carbon emissions, improving sustainable modes of transport, development of energy efficient buildings, etc.

Policy STR3 sets out the need for planning applications to demonstrate how the development ensures adequate accessibility and connectivity, measures to improve sustainable transport, and requirement to produce a Transport Assessment and Travel Plan where necessary, and we welcome this. References have been made in Policy STR3 on how developers are expected to create an environment that encourages walking, cycling and public transport when designing their schemes.

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

Potential impact on the SRN

Based on our review of the Draft Local Plan and the Policies Map, we have identified a few sites from that may have the potential to impact the operation of the SRN in the area. The table overleaf (Table 1) contains the list of potential new housing sites that are likely to have an impact on the SRN in terms of traffic and / or boundary related matters. Please note that we have not included the employment sites in this table as the anticipated land-use and size of developable area are unavailable at this stage. Nonetheless, impacts are expected from employment sites identified in Policy SEC 1- 2,3,5,7,9 and 10 as a minimum.

Should the housing sites listed in Table 1 proceed to the final Local Plan, further assessment work may be required to ascertain the impact on the SRN and to determine the need for any mitigation if required. Whilst we have identified the immediate SRN junctions in close proximity to the housing site allocations where a likely impact is anticipated, it should be noted that the assessments should not be limited to these junctions only and a wider extent needs to be considered based on the scale of the proposed development.

Table 1: List of potential new housing allocations in the Sandwell Draft Local Plan (2022 – 2041) likely to have an impact on the SRN in the area (See attachment)

Impact Assessment

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

We wish to continue to liaise with Sandwell MBC during the development of the Local Plan to understand which sites will be allocated and the potential impacts of these allocations on the SRN. National Highways recommends that a robust transport evidence base in the form of a Strategic Transport Assessment (STA) be produced to support the development of the Local Plan. To support this key piece of work we would recommend the setting up of a Transport Working Group, who can work with Sandwell MBC as the Local Planning Authority to agree the methodology, assessments and infrastructure requirements to support the Plan’s development and adoption.

Black Country Transport Modelling Report (2023)
We note that the Black Country Transport Modelling Report (2023) has been submitted as an evidence base to support the Local Plan and includes the draft scenario assessment, and we welcome this. We acknowledge that the modelling exercise will further be revised in the future as the Local Plan progresses and we look forward to hearing more on this in the Regulation 19 consultation. We have undertaken a high level review of this report and have the following comments:

1. There isn’t enough information available to understand the list of development allocations considered for the modelling exercise. Tables 2-2 and 2-3 of the report indicate the level of population and employment growth on a high-level basis, however no supporting appendices are available that list the development allocations included. Table 2-1 provides a list of the transport schemes coded within the model, and note that M5 J1 has been included in this list as a highway scheme. However, no further detail on the scope/extent of improvement is available. National Highways request clarification.

2. Table 2.1 details the transport schemes added to form the DS network. Several schemes were not included due to agreement between BCLA and the consultants, “…due to negligible impact on the network.” National Highways request some justification/documentation of these decisions.

3. Based on the information set out in section 1 of the report, it is to be understood that the modelling exercise was undertaken to support the Black Country Plan allocations proposed at the time. Also, the modelling report is dated 10 Jan 2023 and therefore, it's highly unlikely that the current set of development allocations proposed in Sandwell and Dudley Draft LP has been included within the development uncertainty log of this PRISM model. National Highways request clarification.

4. Assumptions are only discussed where they differ from the RC work detailed in the previous stage. Our technical partners, are therefore unable to review the unchanged parameters such as highway generalised cost, PT fare, values of time, vehicle operating cost and bus speed etc.. National Highways request this information is provided.

5. Highway model convergence: delta and link cost stability is achieved, but link flow stability (>98% of link with link flow change <1% for 4 successive iterations) appears to be still improving (Tables 3-3 and 3-4). Stopping conditions appear to be too lenient.

6. Observation on numbers of iterations: the DM scenario appears to reach convergence much quicker than the equivalent DS scenario. This is counter intuitive, as the DM and DS have the same levels of development, with the DS having additional transport schemes. Additional capacity usually aids convergence. National Highways request further information from the model appliers.

7. Highway network statistics: average speeds (calculated by veh-km/veh-hr) decline between the RC and DM and the DM and DS. National Highways request some justification/commentary from the model appliers.

8. Flow difference plots. We note the commentary on page 29 and agree. National Highways request results of investigations into the model noise be supplied.

9. Journey time results seem to show that DS has slightly worse network performance than DM, which would benefit from explanation from the model appliers and National Highways requests this. Some large differences also support the previous comments about model noise.

10. If possible, National Highways requests the models are made available for review.

Infrastructure Delivery Plan – Part 1

Policy STR 1 has identified the need for improvements at M5 J1 and J2 to be delivered during the plan period. Following the identification of the improvement measures, we welcome you to have discussions with National Highways at an early stage.

We note that an Infrastructure Delivery Plan (IDP) – Part 1 (Infrastructure Assessment Need) has been submitted along with the Regulation 18 Draft Local Plan. Part 1 of the IDP reflects an understanding of baseline infrastructure capacity and needs within Sandwell and ensures that the implications of future growth upon infrastructure are understood. We understand that Part 2 of the IDP will include an Infrastructure Delivery Schedule and will be published alongside the upcoming Regulation 19 Pre- submission version of the Local Plan. We appreciate that National Highways will be consulted on any infrastructure improvements identified for the SRN in the area and we look forward to engaging with you at the early stage itself.

For information, there is currently no committed funding for this area within the RIS2 and RIS3 planned period and therefore we are keen to understand the monetary implications and what can and cannot be achieved via developer contributions.

Duty to Cooperate

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

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