Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 337
Received: 21/12/2023
Respondent: Seven Homes
Agent: RCA Regeneration Ltd
This policy requires applicants to scope Transport Assessments. Whilst not an unusual requirement, it will be difficult for applicants to adhere to since it is currently not possible to contact a highways officer at the Council. This is because the Council do not have an in-house highway team, but outsource to Amey, who cannot be contacted. This needs to change to allow appropriate scoping to take place prior to the submission of planning applications.
Object
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 361
Received: 12/12/2023
Respondent: Harworth Group
Agent: Claremont Planning Consultancy
Policy DLP69 – The Transport Network
7.1.
Policy DLP69 of the Local Plan requires that new development ensures that an acceptable level of accessibility and safety can be achieved using all modes of transport to, from, and through the development. In support of applications for major development, Policy DLP69 requires the submission of a Transport Assessment that has been scoped and developed in consultation with the Council. The proposed requirement for the scope of Transport Assessments to have been agreed with the Council prior to an application’s submission is not supported. The Planning Practice Guidance (PPG) provides national guidance on the scope of information required to be included within Transport Assessments at Paragraph 15 (reference ID: 42-015-20140306). As an appropriate scope and methodology to inform the preparation of Transport Assessments is established through national guidance, it is not considered necessary or appropriate for the Council to require this to be agreed prior to an application’s submission. Such a requirement is considered to be contrary to national planning policy, and could result in unnecessary delays to the delivery of new development in the Borough.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 475
Received: 19/12/2023
Respondent: Marlie Civils
Agent: RCA Regeneration Ltd
Policy DLP69 Transport Impacts of New Development
2.23. This policy requires applicants to scope Transport Assessments. Whilst not an unusual requirement, it will be difficult for applicants to adhere to since it is currently not possible to contact a highways officer at the Council. This is because the Council do not have an highway team, but outsource to Amey’s, who applicants cannot contact.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 638
Received: 22/12/2023
Respondent: TfWM and WMCA
It is welcoming to see a strong 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. But sustainable travel should always be prioritised above single occupancy car use and it is important everything is done to achieve this within the policies outlined under this header.
We encourage Dudley to consider active travel facilities beyond just storage facilities for vehicles. There are additional facilities, including showers at workplaces, lockers for storage of personal items, charging for e-bikes, etc. that can also help encourage active travel uptake.
While 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 LTP5’s 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 to be able to capture some of these elements.
Comment
Part One: Spatial Strategy and Policies (Regulation 18)
Representation ID: 758
Received: 22/12/2023
Respondent: Canal and River Trust
Cross refencing Policy DLP36 to the justification text for Policy DLP69 Transport Impacts of New Development, will also identify the role of our network in delivering more sustainable travel options, including the use of Travel Plans as a delivery mechanism.