Support, but should also mention Low Traffic Neighbourhoods and EV charging provision

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.

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.

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

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

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

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

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

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

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

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

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

11. Transport Chapter

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

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

Introduction section

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

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

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

Policy STR1 – Priorities for the Development of the Transport Network

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Policy STR3 – Managing Transport Impacts of New Development

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

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

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

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

Policy STR4 – The Efficient Movement of Freight and Logistics

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

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

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

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

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

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

Policy STR5 – Creating Coherent Networks for Cycling and Walking

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

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

Policy STR6 – Influencing the Demand for Travel and Travel Choices

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

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

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

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

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

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

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

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

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

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

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

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

Policy STR9 – Planning for Low Emission Vehicles

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

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

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

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


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

3. Development Strategy
Policy SDS1 – Development Strategy

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

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


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

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

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

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

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

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

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

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

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

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

Conclusion

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

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

Introduction Section

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Policy STR3 – Managing Transport Impacts of New Development

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

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

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

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

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

Policy STR4 – The Efficient Movement of Freight and Logistics

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

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

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

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

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

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

Policy STR5 – Creating Coherent Networks for Cycling and Walking

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

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

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

Policy STR6 – Influencing the Demand for Travel and Travel Choices

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

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

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

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

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

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

Policy STR7 – Network Management

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

Policy STR8 – Parking Management

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

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

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

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

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

Policy STR9 – Planning for Low Emission Vehicles

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

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

Other chapter comments

3. Development Strategy
Policy SDS1 – Development Strategy

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

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


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

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

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

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

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

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

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

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

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

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

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

Conclusion

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

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

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

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

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

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


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

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

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

Clause 3)


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

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

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

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

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

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

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

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

SHE2

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

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

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

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


Para 4.123
Delete ‘ancient’.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Para 13.012 This para would benefit from additional detail.

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

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

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

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