Comment

Representation ID: 32

Received: 30/11/2023

Respondent: Mr George Morran

There is a visible lack of public transport links between Wombourne Sedgley and other transport links in the Black Country.

Comment

Representation ID: 101

Received: 19/12/2023

Respondent: Mrs Ann Kimbley

the excessive amount of heavy road vehicles utilising the centre of Kingswinford as a main route, impedes all traffic including buses.
Diverting/ converting areas within Market Street KIngswinford as vehicle free, would necessitate alteerative arrangements but would provide safety for pedestrians and those with limited mobility to access retail freely.
Enforcement of double yellow road lines appears to be nonexistent, increasing the risk to others. A strengthening of low level minor traffic offence may influence improvements in behaviours to bring longer term benefits.

Comment

Representation ID: 120

Received: 19/12/2023

Respondent: Mr John Davison

A transport network does not work if it is not comfortable to use. The policy fails to mention toilets for bus stations, even though that would be unthinkable at motorway services. A clear case of where land use and transport needs to be coordinated

Comment

Representation ID: 432

Received: 19/01/2024

Respondent: Dudley Labour Group

How will the Council ensure the roads and transport links are able to cope with increased vehicle use and what representations does it intend to make to improve local transport provision to meet the needs of an expanding population?

Comment

Representation ID: 612

Received: 22/12/2023

Respondent: Worcestershire County Council

Transport
WCC is the Local Highway Authority for Worcestershire and is responsible for operating and maintaining the county’s local road network, both in respect of its current activities and needs, as well as its long-term operation and integrity. We are interested in the potential traffic and transport implications of development proposals and/or policies coming forward through the Local Plan process and need to ensure these are fully assessed, understood and where necessary, managed through the plan-making stage(s).
We note that this consultation follows the cessation of work on the Black Country Plan in October 2022, which was being prepared to set out the joint strategic growth targets and policies for the Black Country authorities including Dudley Council. The Draft Dudley Local Plan (DLP) builds on evidence, policies and consultation feedback from work undertaken for the Black Country Plan (BCP) and the Brierley Hill Area Action Plan (BHAAP) Issues and Options consultation (February 2022). WCC provided responses to both the BCP and BHAAP consultations outlining that WCC would welcome further engagement and information regarding the development of the transport evidence base and the implications of the plans on Worcestershire’s highway and transport network.
The DLP area adjoins Worcestershire’s highway network at the A491 Hagley Road, the A4036 Ham Lane and the A456 Birmingham Road/Hagley Hill. These routes provide the key connections between the county and DLP area that may be impacted by growth in Dudley, particularly at Stourbridge, Brierley Hill and Halesowen. We are therefore keen to ensure that transport and land use planning policy is closely integrated, so that the impact of Dudley’s future planned growth on Worcestershire’s transport network is appropriately managed so that the transport network is able to facilitate the delivery of sustainable economic growth across the Plan area.
Relevant Plan-Making Policy – Transport
Our responses to Local Plan consultations are guided by relevant policy and guidance including the National Planning Policy Framework (NPPF), which was most recently updated in December 2023.
The NPPF sets out that plans should be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and statutory consultees (para 16).
Strategic policy-making authorities should collaborate to identify the relevant strategic matters which they need to address in their plans. They should also engage with their local communities and relevant bodies including county councils (para 25).
Effective and on-going joint working between strategic policy-making authorities and relevant bodies is integral to the production of a positively prepared and justified strategy. In particular, joint working should help to determine where additional infrastructure is necessary (para 26).
In order to demonstrate effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these (para 27).
Transport issues should be considered from the earliest stages of plan-making and development proposals so that the potential impact of development on transport networks can be addressed. (para 108).
The planning system should actively manage patterns of growth such that significant development is focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. (para 109).
Planning policies should be prepared with the active involvement of highway authorities and other transport infrastructure providers so that strategies and investments for supporting sustainable transport and development patterns are aligned. (para 110).
Planning policies and decisions should support development that makes efficient use of land, taking into account the availability and capacity of infrastructure and services – both existing and proposed – as well as their potential for further improvement and the scope to promote sustainable travel modes that limit future car use. (para 128).
In terms of identifying the necessity of transport infrastructure, NPPF confirms that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. (para 115).
Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (including transport). Such policies should not undermine the deliverability of the plan. (para 34).
The transport strategy to support the plan will need to be based on a robust evidence base. As a minimum, in order for the transport evidence base to satisfy the requirements of NPPF, it is necessary to establish:
• The transport impacts of the development allocations.
• The improvements necessary to ensure that the impacts are not unacceptable.
• Any land required for the delivery of the necessary improvements.
• The cost of the necessary improvements.
• Any other deliverability constraints.
The Emerging Dudley Local Plan
The DLP will provide for an additional 10,876 new homes and 25ha of employment land across the Dudley Council area for the period up to 2041. The DLP is adopting an urban-led approach, aiming to efficiently utilise previously developed land, vacant properties and surplus industrial land that is well connected and well served by local amenities. To this end, future planned growth across Dudley is primarily focussed towards the borough’s key towns and economic centres. WCC welcomes an urban-led approach to developing the growth strategy and considers that focussing housing growth and development at sites that are located in proximity to public transport corridors/services and employment opportunities, should offer the best opportunities for reducing the need to travel by private car.

As the DLP is developed, it is imperative that any necessary improvements to Worcestershire’s transport network required to successfully deliver sustainable growth aspirations across Dudley borough but particularly Stourbridge, Brierley Hill and Halesowen, are identified, as set out in Government policy, also taking account of strategic growth emerging through the Wyre Forest Local Plan and Bromsgrove District Plan Review. In particular, Worcestershire County Council Highways would welcome further information regarding the intended approach to preparing the necessary transport evidence base and associated infrastructure strategy.

Comment

Representation ID: 636

Received: 22/12/2023

Respondent: TfWM and WMCA

We strongly welcome this Policy and broadly agree with it and the commitment to improving sustainable modes including options for car sharing and potentially micro-mobility. But noting the plan should indicate that the relevant priority rapid transit corridors identified in the LTP5 are as follows:
• Birmingham – Bearwood - Hagley Road – Halesowen
• Walsall – Brierley Hill – Stourbridge, (incorporating Dudley – Brierley Hill)
Longer term proposals further include:
• Hagley Road – Dudley (A4123 corridor)
We also welcome the exploration of road space reallocation for public transport and active travel. Based on the challenges being faced by the region, particularly climate change and decarbonization, it will be difficult to realise improvements without conscious efforts to manage demand for personal vehicle travel.
Cross city bus packages, however, should be moved from the rapid transit section to the Key Road Corridors section as these are not rapid transit.
The aim to provide sustainable and active travel facilities alongside the Metro Extension through Dudley borough is welcomed. But good partnership working with Midlands Metro Alliance to develop these facilities should be explored in this section so good connectivity between different sustainable transport modes can be achieved.
It is very positive that the DLP prioritises highway improvements for public transport and active travel users, rather than drivers. Yet there is mention of transport reflecting existing demand. Within the new WMLTP5 suite of documents, we have adopted a ‘decide and provide’ (rather than ‘predict and provide’) approach to new developments and associated transport enhancements to support them. And while we appreciate the reference to KRN aims within Movement for Growth, WMLTP5 takes this more predict and provide approach to road maintenance and development and so this should be reflected throughout the DLP.
Following on from this in paragraph 16.14, we also encourage connection of Designated Strategic Employment Areas with good public transport and active travel connections which should be a key consideration alongside good links to motorways. Noting a fifth of households don’t have access to a car, it will be important to explore sustainable transport options to such sites, beyond that of car travel.
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 in this section to Strategic Road Network Designated Routes for Unplanned Events (DRUEs).
We further welcome reference to coaches and their role in providing affordable long-distance connectivity, but we would appreciate more specific policies or actions detailing the promotion of coaches in the borough.
Also, it is important to note in this section some minor amendments are required, and these are as follows:
• Page 328 Amend Bullet points to read
o West Midlands Rail Executive - Single Network Vision (WMRE 2017)
o Driving a Revolution in Rail Services for West Midlands - A 30-year West Midlands Rail Investment Strategy 2022-2050 (WMRE 2023)
o Midlands Connect Strategic Transport Plan (updated in 2021/22)
o Midlands Rail Hub OBC (2022)
• Page 329
o West Midlands Rail Investment Plan Strategy
It may also be important to note that following the cancellation of HS2 Phase 2, there may be some challenges in delivering all of our rail ambitions across the Black Country. In particular, Phase 2A of HS2 to Crewe would have provided an alternative rail route around the West Midlands conurbation, which in turn would have released some capacity on the Birmingham - Wolverhampton/Walsall – Staffordshire rail corridors that could have been used to improve local and regional rail services and provided a second hourly Wolverhampton – Sandwell & Dudley – London Euston service.
To conclude, clearly several measures are moving in a positive direction in terms of delivering on a good, integrated transport network. Yet 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. Therefore, continued partnership working with TfWM will be essential in this.

Comment

Representation ID: 693

Received: 15/12/2023

Respondent: National Highways

We acknowledge that the Draft Local Plan has specifically focussed on policies to tackle climate change by reduction in carbon emissions, improving sustainable modes of transport and development of energy efficient buildings which is welcomed.
DLP 67 sets out the need for planning applications to demonstrate how the development ensures adequate accessibility and connectivity, and measures to improve sustainable transport. References have been made in Policy DLP 67 on how developers are expected to create an environment that encourages walking, cycling and public transport when designing their schemes .

Comment

Representation ID: 698

Received: 15/12/2023

Respondent: National Highways

DLP 67 states that the following priority transport schemes have been identified for delivery on the SRN:
•M6 Junction 10
•M5 Improvements (Junctions 1 and 2, including Birchley Island)
•M54 - M6/ M6 (Toll) Link Road
We acknowledge that the improvements at M6 Junction 10 are under construction through RIS scheme and M54 – M6 Link Road is committed for the second Road Period (RP2). However, for the M5 junctions, we ask you setup discussions with National Highways as soon as possible to enable a successful regulation 19 process.

Comment

Representation ID: 757

Received: 22/12/2023

Respondent: Canal and River Trust

Trust seeks explicit mention of the canal network within either policy wording or justification text for Policy DLP67 The Transport Network, to reflect our identification as a delivery agency within para 16.18. (ACTION REQUEST).

Comment

Representation ID: 822

Received: 30/01/2024

Respondent: Historic England

DLP67. How has the historic environment been considered in the process of assessing transport infrastructure needs? What heritage impact assessment has taken place when assessing which transport networks to allocate/safeguard through this policy?