Comment

Representation ID: 639

Received: 22/12/2023

Respondent: TfWM and WMCA

We welcome this policy, and the role new technologies and modal shift 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.
With the noticeable increase in van traffic across the region due to a combination of factors including the increase in online shopping, we welcome the consideration of last mile logistics and shifting freight movements from road transport to more sustainable modes where possible. Improving rail infrastructure will aid in this, but there should be explicit policy from Dudley to facilitate modal shift.
We recognise the use that reinstating disused rail lines can have on improving rail capacity, but we encourage Dudley to set out specific plans for how they will deliver this in the borough. Note that the Wednesbury – Brierley Hill tram line is currently under construction on part of the former railway alignment between Walsall and Stourbridge. Reinstatement of this route for rail freight services would require some form of shared use solution (e.g. use of tram-train vehicles on West Midlands Metro services)
There is omission 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. This is especially important along the key routes of the M5 and M6 so considering policies which could address this would be welcomed.
Under this policy we would also 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.
While in the justification section in paragraph 16.34 it promotes the use of low emission vehicles and the use of parcel lockers, emphasising this in the actual policy section, along with e-cargo bikes and use of micromobility would further be welcomed, especially for those last mile journeys.
Finally, we encourage consideration of charging needs for sustainably fuelled freight vehicles. Charging provision for personal vehicles is important, but there also needs to be plans in place for where electric LGV’s and HGV’s will most need to refuel.

Comment

Representation ID: 694

Received: 15/12/2023

Respondent: National Highways

Policies DLP 70 (The Movement of Freight), DLP 71 (Active Travel) and DLP 72 (Demand for Travel and Travel Choices) sets guidelines on improving the sustainable transport. We appreciate the effort taken in developing these policies and consider this to be aligned with the expectations set out in the National Planning Policy Framework and National Highways’ Net Zero Strategy.
Impact Assessment
Any potential site that is anticipated to have an impact on the SRN in the area is recommended to be subject to consultation with National Highways, and appropriately assessed in line with the Department for Transport (DfT) Circular 01/2022 to determine the extent of their potential impacts on the SRN in the area. Depending on the scale of likely impact on the SRN in the area, the developer may need to identify suitable mitigation measures (if required). We welcome that Policy DLP 69 that all the developments are required to submit a Transport Assessment (TA) or a Transport Statement (TS) along with a Travel Plan (TP).
It is to be noted that the cumulative impact of the proposed site allocations also needs to be assessed in line with the Circular for understanding the likely traffic impacts on the SRN in the area in terms of capacity & safety and identifying any possible mitigation measures (if required).
We wish to continue to liaise with Dudley MBC during the development of the Local Plan to understand which sites will be allocated and the potential impacts of these allocations on the SRN. National Highways recommends that a robust transport evidence base in the form of a Strategic Transport Assessment (STA) be produced to support the development of the Local Plan which should be reflected in their Regulation 19 evidence. To support this key piece of work we would recommend the setting up of a Transport Working Group, who can work with Dudley MBC as the Local Planning Authority to agree the methodology, assessments, and infrastructure requirements to support the Plan’s development and adoption.

Comment

Representation ID: 759

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests mention of the potential use of the waterways within the justification text to Policy DLP70.