Part One: Spatial Strategy and Policies (Regulation 19)

Support

Representation ID: 1597

Received: 29/11/2024

Respondent: National Highways

Agree in principle to the vision and objectives of the Plan.

Comment

Representation ID: 1598

Received: 29/11/2024

Respondent: National Highways

Note the housing and employment requirements have changed since the Regulation 18 consultation.

Note housing shortfall and welcome Council's initiative to address this through the Duty to Cooperate- would welcome update to understand how the impacts from unmet housing need will be captured.

Table 5.1 indicates a total of 5,395 dwellings as allocations whilst the Part Two Housing allocation details reflects a total of 4,569 dwellings. Welcome clarity on the allocations and recommend an update in the Local Plan for consistency.

Note the employment land shortfall and the removal of allocations since Regulation 18.

Support

Representation ID: 1600

Received: 29/11/2024

Respondent: National Highways

COMMENT ON SUSTAINABILITY APPRAISAL.

Acknowledge receipt of document. Note that new development allocations are focused within Regeneration Areas and Centres which is likely to result in a more efficient use of land while enhancing the sustainable travel options. This is welcomed.

Support

Representation ID: 1601

Received: 29/11/2024

Respondent: National Highways

Acknowledge the Local Plan has focused on policies DLP41 - DLP48 to tackle climate change by reduction in carbon emissions, improving sustainable modes of transport and the development of energy efficient infrastructure which is welcomed.

Support

Representation ID: 1602

Received: 29/11/2024

Respondent: National Highways

We note that the policy remains the same as included in the Regulation 18 consultation and welcome this. Particular reference made to planning applications requirements and expectations for new schemes and active travel.

Comment

Representation ID: 1603

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON TRANSPORT EVIDENCE BASE AND IMPACT ASSESSMENT

Impact Assessment
Any potential sites anticipated to have an impact on the SRN are recommended to be subject to consultation with National Highways, and appropriately assessed in line with the Department for Transport (DfT) Circular 01/2022.

The cumulative impact of site allocations also needs to be assessed in line with this guidance.

Black Country Transport Modelling Report

Have reviewed 2024 modelling report published as part of the Regulation 19 consultation. Several comments to make to seek clarity:
- How have COVID-19 impacts been accounted for.
- Clarification on when NTEM is referenced what version/scenario this is.
- Clarification on the forecasting approach- only single forecast presented.
- Information on the derivation of any new parameters developed.
- Information to help understand the stability of the model outputs.

Comments also submitted to Sandwell Reg 19 Local Plan and in the process of reviewing a response note provided.

Support

Representation ID: 1605

Received: 29/11/2024

Respondent: National Highways

any potential sites anticipated to have an impact on the SRN in the area are recommended to be subject to consultation with National Highways, and appropriately assessed in line with the Department for Transport (DfT) Circular 01/2022. Also applies to cumulative impacts of proposed site allocations.

Welcome that Policy DLP 69 requires all the developments to submit a Transport Assessment (TA) or a Transport Statement (TS) along with a Travel Plan (TP), based on the size and scale of the development proposed.

Comment

Representation ID: 1607

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON INFRASTRUCTURE DELIVERY PLAN

Note that the transport modelling work was not completed during its preparation and therefore, the specific infrastructure and mitigation requirements are yet to be finalised. We look forward to reviewing the finalised list once it is available.

Updates provided on some projects within the table.

Acknowledge several transport schemes to improve active travel and public transport are identified.

Comment

Representation ID: 1608

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON DUTY TO COOPERATE

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

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