Key to Second Deposit Written Statement text - Added text and deleted text
 

CHAPTER 14: ACCESS AND MOBILITY

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14.1 Introduction 222
14.1.2 Wolverhampton - The Accessible City 222
   
14.2 Access, Mobility and New Development 223
Policy AM1: Access, Mobility and New Development (Part I) 223
   
14.3 Strategic Regeneration Areas and Corridors - Transport Investment 224
Policy AM2: Strategic Regeneration Areas and Corridors - Transport Investment 224
   
14.4 Major Transport Schemes 226
Policy AM3: Major Transport Schemes 226
   
14.5 Strategic Highway Network 227
Policy AM4: Strategic Highway Network 227
   
14.6 Protection of Highway Improvement Lines 228
Policy AM5: Protection of Highway Improvement Lines 228
   
14.7 Transport Assessments 229
Policy AM6: Transport Assessments 229
   
14.8 Travel Plans 230
Policy AM7: Travel Plans 230
   
14.9 Public Transport 231
Policy AM8: Public Transport 231
14.9.8 Bus Provision 232
14.9.12 The Local Rail Network 232
14.9.16 Light Rail / Light Rapid Transit 233
   
14.10 Provision for Pedestrians 233
Policy AM9: Provision for Pedestrians 233
   
14.11 Provision for Cyclists 234
Policy AM10: Provision for Cyclists 234
   
14.12 Park and Ride 236
Policy AM11: Park and Ride 236
   
14.13 Car Parking and Servicing Provision 237
Policy AM12: Car Parking Provision 237
   
14.14 Development of Freight Facilities 240
Policy AM13: Development of Freight Facilities 240
   
14.15 Minimising the Effect of Traffic on Communities 241
Policy AM14: Minimising the Effect of Traffic on Communities 241
   
14.16 Road Safety and Personal Security 241
  Policy AM15: Road Safety and Personal Security 241
 
 
   
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14.1

Introduction

14.1.1 Transport is not an end in itself but a means to ensure good access for people to facilities and services and for the movement of people and goods to promote the area's economic, environmental and social well being. The policies in this Chapter underpin many of the guiding principles of the Plan in the following manner:
  Economic Development and Regeneration - High quality transport links are essential for new investment to maintain and enhance the viability and vitality of our City and Town Centres.
  Sustainable Development - The Council is committed to developing a transport system that supports a sustainable pattern of development so minimising adverse environmental impacts and ensuring the most efficient use of energy.
  Social Inclusion and Equality- Access to economic, educational and social opportunities are integral to our quality of life.
  Health and Safety - Improvements in our transportation systems are designed to reduce accidents, improve personal security and encourage people to lead more active lifestyles by walking and cycling. There is a direct link between employment and health and providing access to employment, especially for those without access to a car is therefore a priority issue.
  Quality of Life and Environment - A high quality environment with good urban design standards is essential to improve people's sense of 'well-being'.
   
Wolverhampton - The Accessible City
14.1.2 The challenge we face is to improve mobility, accessibility and therefore the area's economic vitality, whilst at the same time managing the demand for transport, and raising the quality of life of our communities. This requires creative and innovative solutions and new ways of addressing our transport needs in particular increasing the travel and transport choice and encouraging a more sustainable approach. We need to provide the information necessary to enable individuals and organisations to gain the confidence to change their travel habits and established practices. We then need to deliver standards of service that meet people's expectations.
14.1.3 A prosperous economy and high quality of life depends on people having access to the full range of services and opportunities for work, training, shopping, and leisure. Most of us travel every day even if only locally. Access to opportunities for work, training, education or leisure, be they local or further afield are crucial in supporting our regeneration efforts, particularly in those areas of the City that suffer from multiple problems of economic, social exclusion, and poor environmental quality. Access and Mobility for people and goods are essential ingredients to generate wealth and economic opportunity.
14.1.4 The principles guiding the Access and Mobility policies for Wolverhampton are to:
 
  • Promote access and mobility for all
  • Provide increased choice of mode of travel and to inform people of the opportunities
  • Encourage environmental sustainability and efficient use of resources
  • Reduce congestion and its cost to the local economy
  • Provide a high quality built environment
  • Improve safety and personal security by better design
  • Support employment growth
  • Integrate the different modes of transport
  • Provide people with information on travel choices
  • Improve the health of the community
   
   
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14.1.5 In partnership with transport providers, developers and others the Transportation Programme will therefore need to:
 
  • Support employment growth by ensuring there is good access and a real choice of mode of transport for people to take up new job opportunities, especially the physically disadvantaged and those from the more deprived neighbourhoods.
  • Improve access, mobility, image, attractiveness and security of the City and Town Centres to enhance their vitality and viability.
  • Promote the quality, reliability, image and attractiveness of the public transport network to meet peoples' expectations.
  • Extend and develop a high quality light rail system along key transport corridors.
  • Improve the environment for pedestrians and cyclists to encourage these as sustainable and healthy modes of travel.
  • Reduce the adverse impact of traffic on local communities by reducing the volume of traffic and related air and noise pollution.
  • Improve safety and personal security for all, especially the more vulnerable groups in society.
  • Provide a strategy for car parking in the City in collaboration with colleagues across the wider West Midlands Region
  • Provide the context for the introduction of Travel Management Tools such as Travel Plans
  • Improve the health of individuals by encouraging more environmentally sustainable transport choices and more active lifestyles.
14.1.6 The Wolverhampton Unitary Development Plan reflects Regional objectives set out in Regional Planning Guidance and the Council's Transport Strategy expressed through successive Local Transport Plans prepared in partnership with the other Metropolitan Districts and Centro. It is influenced by the findings of the West Midlands Area Multi-Modal Study (WMAMMS) and other recent Government-led transport studies (see Chapter 1).
   
 
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14.2

Access, Mobility and New Development

Policy AM1: Access, Mobility and New Development (Part I)
 
The Council will work in partnership with Centro, neighbouring authorities, the health community, business sector and transport operators to improve access and mobility for all members of the community.
All new development will be expected to contribute towards improvements in access and mobility, by ensuring that people have a wide choice of mode of transport to access the site, including public transport, cycling and walking. Such contributions will be sought in accordance with UDP Policy IMR2 ‘Planning Obligations and Agreements.’ (1)
Development that attracts a large number of people and traffic should be located in areas well served by public transport, so making effective use of existing transport infrastructure and providing real transport choices for the movement of people and goods.
All development should be designed to minimise the adverse effects of any roads and traffic on neighbouring residential areas or other sensitive uses.
The detailed design of new development must make provision for all modes of transport and the needs of people with disabilities (2). Access to and, where appropriate, (3) around the development on foot, by bicycle and by public transport should be given priority the highest priority (4) in the layout and detailed design (see Policy D3). Car parking provision and design should comply with the Council's Supplementary Planning Guidance and policies in the Design Chapter. New commercial development in existing streets and centres will be required to include rear-servicing facilities.
   
   
   
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14.2.1 All new development should be widely accessible and offer people travel choices. The success of new development depends on how well it is connected to the wider road network, neighbouring streets, public transport routes, cycle routes and footpaths. These links should give people the maximum choice in how to make their journeys and should give a high priority to walking, cycling and public transport.
14.2.2 Maximising travel choice for people means creating routes that are felt to be safe, attractive and direct. Segregated routes for walking and cycling are not always the best way to create a safe and secure environment and where provided need to be sensitively designed. Success of a development is not just measured in terms of functional performance but also how the development contributes to the quality and character of the City (see Chapter 4: Design).
14.2.3 The strategy for car parking is important to the success of a new development. The level of provision should be determined in the light of current Government Guidance and the Council's Supplementary Planning Guidance. Buildings, and the spaces around them, should be designed to help control the flow and density of traffic and be designed to complement the new development and improve the local environment.
14.2.4 The Council will seek to ensure that the design of new development will provide off-street servicing wherever possible and preferably from rear access roads in order to reduce nuisance and conflicts between service vehicles and other road users.
   
 
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14.3

Strategic Regeneration Areas and Corridors - Transport Investment

Policy AM2: Strategic Regeneration Areas and Corridors - Transport Investment
 
Transport investment will be focused on identified Strategic Regeneration Areas and Corridors (see Policies SH1 and SH2), to provide improved public transport, cycle and pedestrian facilities and other measures to address traffic congestion and better management of the Strategic Highway Network (5).
Park and Ride sites and associated public transport improvements will be identified along these corridors to serve Wolverhampton and the Black Country. Further extensions to Midland Metro Line 1 will be investigated, to serve the route from Wolverhampton to Wednesfield and on to Walsall in the next 5-8 years, and other corridors in the longer term. The feasibility of a new railway station to serve Strategic Park and Ride to the north of Wolverhampton will also be considered development of a new railway station to serve strategic Park and Ride to the north of Wolverhampton at Brinsford in South Staffordshire will be supported (6) .
   
14.3.1 The Strategic Regeneration Areas and Corridors identified in Policies S1 and S2 are all located within the Walsall, Wolverhampton and South Staffordshire Regeneration Zone and these will be subject to significant development and change over the Plan period. The Black Country Route and Birmingham New Road transport corridors and the City Ring Road are also of strategic significance for transport.
14.3.2 Within these areas and corridors particular attention will be given to transport investment to improve public transport, cycle and pedestrian facilities and introduce measures to tackle traffic congestion to support employment investment. The need to create better links between the areas and corridors and the nearby 'Priority Neighbourhoods' is also considered to be important.
   
   
   
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14.3.3 Park and Ride sites will be identified to serve Wolverhampton City Centre and the wider West Midland's Region and complemented by the public transport priority measures being developed along these transport corridors. This will encourage people to switch from their car to public transport for the most congested part of the journey (6)
14.3.4 New railway stations and a phased extension to the Midland Metro Light Rail Network are also being investigated to serve some key regeneration corridors and strategic development sites.
14.3.5 Particular transport investment proposals are listed below. Others are identified in Policies AM3 and AM8 and the Wolverhampton City Centre, Bilston Town Centre and Wednesfield Village Centre.
   
A449 Stafford Road Corridor
14.3.6 Short Term (0-3 years) Transportation Schemes include:
 
  • The designation of the route as a 'Red Route' to maximise efficient use of the highway.
  • The development of a Bus Showcase along the A449 into the City Centre.
  These measures are now in hand and will be largely implemented during 2003 / 04.
  Medium Term Measures (3-5 years):
 
  • New and improved access to the Wobaston Road Regional / Premium (RIS) and Major Investment sites (MIS) including a priority given to access by public transport (8).
  Long Term Measures (5-10 years):
 
  • Identification and designation of a Park and Ride site to the north of the City at Brinsford in South Staffordshire District. This would be achieved in collaboration with South Staffordshire District Council and Staffordshire County Council. It is hoped to serve the site by a new railway station and bus priority measures
A41 Bilston Road, Black Country Route and Spine Road Corridor
14.3.7 The corridor already has the benefit of the Midland Metro Line 1. Further investment in transport along this corridor will be influenced by the development of Bilston Urban Village and the needs of Bilston Town Centre.
 
A4124 Wednesfield Road
14.3.8 Wednesfield Way completed in 1998 provides a bypass to Wednesfield centre and good access to new employment sites. The Bus Showcase scheme in this corridor provides high quality bus links along this corridor.
  Short Term Measures (0-3 years)
 
  • Junction improvements to improve capacity of the highway and provide opportunities to improve the reliability of public transport · Improving accessibility to New Cross Hospital in partnership with the Health Trusts
   
   
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  Medium Term Measures (3-5 years)
 
  • Investigate running the Midland Metro along the A4124 corridor to Walsall and serving the New Cross Hospital (5 Ws Route).
  • Development of the City Centre Interchange Scheme (including the enhancement and redevelopment of the Railway Station and further enhancements to the Bus Stations)
  Long Term Measures (5-10 years)
 
  • Development of Midland Metro proposals · Implementation of the 5 Ws Metro Route
 
A454 Willenhall Road
  14.3.9 This corridor already has the benefit of a Bus Showcase route. Future investment along this corridor will be considered in order to further enhance public transport reliability.
 
A4123 Birmingham New Road
14.3.10 Investment in transport along this corridor will be considered in order to enhance public transport reliability.
   
City Ring Road
14.3.11 The Ring Road serves a vital function as the collector and distributor of traffic from the 10 radial routes that focus on the City Centre. A number of studies undertaken in recent years have highlighted the barrier effect of the Ring Road to movement of people, particularly pedestrians and cyclists, into the city from outlying neighbourhoods. Development is now being promoted on sites outside the City's Ring Road and a preliminary study has been commissioned to determine some short-term measures to improve conditions for pedestrians and cyclists who wish to cross the Ring Road. It is essential that this is delivered without impairing traffic capacity.
14.3.12 Further work is being commissioned to evaluate longer-term options for alternatives to collect and distribute Wolverhampton's through-traffic more efficiently and to consider options to provide safer, more attractive, convenient and direct crossings of the Ring Road for pedestrians. This study will influence the medium and long-term role for the Ring Road.
   
 
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14.4

Major Transport Schemes

Policy AM3: Major Transport Schemes
 
In addition to the measures highlighted in Policy AM2, the following are considered to be priority major transport schemes:
  • Strategic Park and Ride sites on the edge of the conurbation to serve commuters travelling in to Wolverhampton and elsewhere in the West Midlands conurbation. Priority will be given to identifying sites to the north and west of the conurbation;
  • Public transport improvements along the Strategic Highway Network and serving both local and strategic Park and Ride sites;
  • Local Park and Ride sites linked to public transport (bus, tram and rail) for shoppers and city centre workers to support the economic vitality of the City Centre;
  • Promotion of Bus Showcase and Super Showcase together with related traffic management measures along the Strategic Highway Network;
  • The further development of Midland Metro;
  • Improvements to rail infrastructure to improve local links within the region and to enhance Wolverhampton railway station as befits its location on the Intercity Network including the four-tracking of the West Coast Mainline between Wolverhampton and Coventry (9);
  • Implementation of the Wolverhampton Interchange Scheme that seeks to integrate rail, Metro and bus services in the City Centre;
  • Traffic Management Measures to ensure maximum efficiency of the Strategic Highway Network and reduced impact of traffic and transport on local communities;
  • Maintenance of the highway network.
  • National Cycle Network Route 81 (10)
   
   
   
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14.4.1 The Council has identified the major transport schemes outlined in Policy AM3 to be a priority for the investment programme in the short, medium and long term. Resources for implementation will be sought from the Transport Settlement through the Local Transport Plan bidding process and from developers and others funding sources as appropriate.
   
 
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14.5

Strategic Highway Network

Policy AM4: Strategic Highway Network
 
Priority will be given to maintaining and improving the Strategic Highway Network as a means of supporting the economic regeneration of the City. This work will be undertaken to complement the promotion of public transport, cycling and walking to reduce the impact of traffic on local communities as detailed elsewhere in the UDP.
   
14.5.1 The Strategic Highway Network (SHN) incorporates the Department of Transport defined Primary Route Network (PRN) linking primary destinations and distinguished by the green background route information signs and other roads of more than local importance. These latter routes have been determined against the following criteria for inclusion in the SHN:
  a) Large volumes of traffic use the route;
  b) A substantial proportion of the traffic on the route is long distance through-traffic without ready access to the motorway or Primary Route Network (PRN);
  c) The routes carry significant numbers of heavy goods vehicles;
  d) The routes link major industrial or commercial developments and centres of population together or to the PRN; and
  e) The routes make a significant contribution to urban regeneration.
14.5.2 Within Wolverhampton the network comprises the main routes radiating from the City Centre Ring Road, together with the A4039 and A463 and the Black Country Route. The Strategic Highway Network is shown on the Proposals Map.
   
   
   
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14.6

Protection of Highway Improvement Lines

Policy AM5: Protection of Highway Improvement Lines
 
To avoid the unnecessary blighting of land improvement lines will only be maintained in the following circumstances:
a) On the SHN where improvements are envisaged;
b) Where required for specific schemes not on the SHN but identified in a current programme;
c) In exceptional circumstances where it is necessary to introduce or maintain an improvement line for a scheme even though it is not in a current programme;
d) Where it is essential for the achievement of Centro's 20-Year Strategy for Public Transport.
Priority will be given to maintaining and improving roads on the Strategic Highway Network as the means of supporting the economic regeneration of the City and accommodating traffic of more than local significance. The Proposals Map also identifies road junctions and highway where improvements are required during the Plan period.
 
 
14.6.1 Priority will be given to maintaining and improving roads on the Strategic Highway Network as the means of supporting the economic regeneration of the City and accommodating traffic of more than local significance. The Proposals Map also identifies road junctions and highway where improvements are required during the Plan period. Priority will be given to protecting improvement lines on the Strategic Highway Network as the means of supporting economic regeneration and the Council’s transport strategy. The Proposals Map identifies highway improvements that are required during the Plan period. (11) [Maps 14/1, 15/1, 15/2, 15/3, 17/3, 17/4]
14.6.2 The purpose of improvement lines is to protect land required for highway schemes from other development. Long-term improvement schemes will continue to be protected from other development, although they may be brought forward in conjunction with development proposals. Current proposed highway improvement lines are listed in Appendix 3 and shown on the Proposals Map. The programme for minor schemes is prepared only one or two years in advance and schemes in the programme are likely to change for a variety of reasons. Consequently, the minor scheme programme cannot be listed for the Plan period. A number of highway improvement lines exist on roads not forming part of the SHN. The Highways Agency will be consulted on those that may have an effect on the trunk road network. (12)
14.6.3 Certain junctions and highways are identified on the Proposals Map as requiring improvements during the Plan period. [Maps 14/2] These are considered in two categories, those schemes that will be designed and implemented during the Plan period and those where further investigation is required before the exact improvements can be defined.
14.6.4 The SHN includes those key transport routes that have a regional role and require a high capacity and relatively free flow of traffic. The Council will target investment to increase accessibility along selected elements of the SHN, whilst giving a high priority to road safety and local environmental improvements.
14.6.5 On those roads that are not part of the SHN the presumption is that local considerations should predominate. Issues such as environmental impact, safety, the needs of public transport, pedestrians and cyclists will be key factors in planning future development and determining planning applications.
14.6.6 Centro's 20-Year Strategy identifies a number of transport corridors that are considered important or have potential for development for high-volume public transport services. These routes will be investigated for Bus Priority Measures and, in the longer term for guided bus schemes and light rapid transit schemes.
   
   
   
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14.7

Transport Assessments

Policy AM6: Transport Assessments
 
The Council will require Transport Assessments to be submitted with all planning applications for development proposals that have significant implications for transport in accordance with PPG13. Smaller developments will require a Transport Assessment where it is anticipated that there will be significant transport implications resulting from the development or cumulatively with other proposed developments in the area. They may also be required at sensitive locations where the Council is seeking to reduce current levels of road traffic and to widen the transport choice for people.
The scope and content of the Transport Assessment will need to reflect the scale of the development but as a minimum will need to show for more significant proposals will be expected to include (13):
a) The transport impacts of the development;
b) Accessibility to the site by all modes;
c) Current and proposed modal split of journeys to and from the site;
d) Details of proposed measures to improve access by public transport, walking and cycling, to reduce the need for parking and to mitigate against transport impacts; and
e) How safety is to be improved.
The assessments will be used to determine the transport impact of the development and whether developers will be required to prepare and implement a Travel Plan for their development in accordance with Policy AM7. They will also determine the need for the developer to implement transport improvement measures on and/or 'off-site' or to make contributions to the Council to implement such measures in order to ameliorate the impact of additional generated traffic. These will be sought in accordance with Policy IMR2: Planning Obligations and in line with current Government guidance.
 
 
14.7.1 All major developments that are considered to have the potential to generate significant numbers of trips will be required to produce Transport Assessments. These need to indicate how the transport implications of the proposal are to be addressed. Also, smaller developments that, taken together, will have a significant transport impact will each require a Transport Assessment. The Government has made a commitment to produce guidance on the scope, content and methodology of TAs and developers should refer to this when it becomes available.
14.7.2 Transport Assessments are needed to allow the Council to assess the traffic implications of development proposals for all modes of transport. They will determine whether or not these proposals deliver sustainable transport objectives and will provide a basis for negotiation on the details of schemes, such as the level of parking, provision of a choice of transport, and measures to improve site access arrangements and off-site works required. They will also indicate the need for a Travel Plan to be developed and implemented for the development.
   
   
   
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14.8

Travel Plans

Policy AM7: Travel Plans
 
Where it is considered that a development proposal will generate significant traffic or where a Transport Assessment highlights the need for a Travel Plan, a Travel Plan (TP) should be submitted with the planning application and implemented if planning permission is granted. Developers will be required to prepare a Travel Plan (TP) where a need is suggested by a Transport Assessment or other circumstances. A TP will normally may be required to be submitted and agreed by the Council before an application is determined or alternatively before a development is occupied the development is occupied (14). Unacceptable development will not be permitted because of the existence of a TP.
A TP will include proposals for reducing the number of journeys generated by developments through actions such as encouraging reduced car use, reducing traffic speeds, improving safety, increasing the number of journeys done on foot or by bicycle, and improving access by public transport. A TP should also promote more environmentally friendly delivery and freight movements. Specific proposals included within the TP will be measured against agreed targets in order to show that the sustainable transport objectives are being achieved.
The Council and Centro (West Midlands Passenger Transport Executive) will provide assistance with the preparation of the TP. The final TP will need to be agreed with the Council either before the planning application can be approved or before a development is occupied, depending on the nature of the development. It may not be possible to approve an application without evidence that travel demand which would be generated can be satisfactorily managed. (15)
The Council would recommend that all organisations consider adopting a TP as a management tool in order to reduce the impact of traffic generated from the site/s and improve business efficiency.
 
14.8.1 A Travel Plan is a management tool that brings together transport and other business issues in a co-ordinated strategy. It should be an integral part of good business practice in the same way as pollution and waste management has become in recent years. In short they are a package of measures aimed at reducing car-use, improving access to the site, and improving efficiency by targeting commuter journeys, customer access, business travel and fleet management. As a business tool they can address parking and accessibility problems, widen the labour pool, overcome the transportation problems that are barriers to obtaining planning consent, reduce company costs by reducing business mileage, and enhance a Companies environmental credentials and image.
14.8.2 The Council proposes to adopt its own Travel Plan and encourage their adoption by other organisations such as businesses, schools, hospitals and other organisations that generate significant numbers of journeys.
14.8.3 The Travel Plan (TP) package of measures can be tailored to the needs of individual organisations or sites. The Plans seek to manage demand for travel, to develop attractive alternatives to the car, and to use transport more efficiently through better organisation. It will highlight any opportunities to provide more environmentally friendly transport and gaps in transportation provision locally. A TP is a dynamic process that needs to adapt and change with time and changed circumstances. It should also assist organisations to encourage staff and visitors to think about their travel needs and choices and to use more environmentally sustainable modes. It should influence all travel, including the journey to work, business travel, visitors, deliveries and contractors and fleet vehicles.
   
   
   
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14.9

Public Transport

Policy AM8: Public Transport
 
The provision of a high quality, comprehensive and integrated public transport network to meet local and longer distance travel needs in the City will be pursued by:
a) Working in partnership with Centro and transport operators;
b) Working to ensure that communities and neighbourhoods are well served by public transport facilities that meet their needs;
c) Ensuring that new developments are well served by public transport and, where appropriate, that improved facilities and services are provided by developers as the site is occupied;
d) Taking the public transport needs of vulnerable groups into account Taking the public transport needs of vulnerable groups into account including users of ‘ring and ride’ services (16);
e) Providing enhanced passenger waiting and information facilities, better bus/rail/metro interchanges and better provision for cyclists to transfer to public transport;
f) Providing improved access by foot to bus stops, metro stops and railway stations;
g) Improving rail and bus accessibility to Birmingham International Airport;
h) Providing Park and Ride Car Park sites to serve the City and the wider sub-region and linked to improved bus, tram and rail services;
i) Taking into account the need to provide for taxi services within the larger development proposals, particularly in Wolverhampton City Centre and at transport interchanges.
 
   
14.9.1 Whilst the Council does not directly provide public transport services it has an important enabling role as the Highway and Planning Authority. The West Midlands Passenger Transport Authority (WMPTA) is the policy making body for local public transport and Centro implements it's policies. Centro is responsible for procuring local rail services, it funds concessionary fares, provides bus facilities, information, special needs transport and plans for future public transport. Private companies run the range of public transport services.
14.9.2 A high quality and integrated public transport network is essential for economic revitalisation, accessibility and social inclusion and sustainable travel patterns. Bus, Rail and Metro are brought together within a strategic public transport network that is being promoted across the West Midlands Metropolitan area by Centro and the Metropolitan District Councils Authorities (17).
14.9.3 The Council is working with Centro, transport operators and community groups to ensure that public transport provision meets the needs of local communities and provides the means by which people can access employment, training, health facilities and leisure opportunities.
14.9.4 In this context it is important that new developments are readily accessible by all sectors of the community and that the ability to use facilities is not dependent on the availability of a car. Transport Assessments for all major new developments will determine the overall transport requirements of a proposal and developers will be required to provide appropriate public transport services and facilities to serve the new development (see Policy AM6).
   
   
   
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14.9.5 Equality of access for all the residents of the City to jobs, homes, shops, social leisure facilities and education and training is a key objective of the Council. The need to combat social exclusion is paramount and the City Council is actively ensuring that the needs of vulnerable groups are catered for on the local transport network.
14.9.6 The UDP is seeking to ensure that transport contributes to social inclusion by increasing accessibility for everyone. This includes those who:
 
  • Cannot afford a car or those family members who do not have access to a car
  • Have mobility problems, and
  • Choose not to, or prefer not to own a car.
  The elderly, those with child-care responsibilities and people with disabilities are three groups within the community who could benefit significantly by this approach.
14.9.7 The provision of better information on the public transport network will help generate confidence in the network, help people understand the services that are available and the travel opportunities that are provided.
   
Bus Provision
14.9.8 The key element of an integrated and improved public transport service is the bus network. Over 90% of public transport journeys are currently made by bus. Even with the expansion of the Metro and rail networks the bus network will continue to carry the majority of public transport users. The Council recognises the importance of the bus network in the City and by working with operators will seek to bring forward improvements that generate efficiency savings for operators and provide the public with an attractive alternative to the private car.
14.9.9 The standards for the quality, location, and level of provision of bus stops and related facilities will accord with those stated in Centro's 20-Year Strategy. New development should provide for a direct bus route or, failing that, direct access to an existing route.
14.9.10 What matters most is:
 
  • Clear direct and safe routes to bus stops including well-placed road crossings;
  • Locating bus stops close to where activity is taking place and away from locations where people feel vulnerable;
  • Providing clear unambiguous information on bus routes, service frequencies, tickets and fares.
14.9.11 Bus priority measures and higher quality services through the Bus Showcase initiative will enable buses to run more reliably and more effectively, making bus travel more attractive for everyone.
   
The Local Passenger Rail Network
14.9.12 The Council will encourage and promote the use development and improvement of the local passenger rail network to increase the number of passenger journeys and the movement of freight by rail. Existing rail facilities for passengers and freight will be safeguarded except where agreed as surplus to current or possible future operational requirements. The Council will investigate with Centro, Railtrack and train operators the potential for new stations and new freight facilities within the City to serve existing uses, new development sites and new Park and Ride sites. (18)
   
   
   
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14.9.13 Redundant Rail Lines and rail-heads which are considered to have potential for reuse either for rail or for pedestrian and cycle facilities will be protected to prevent prejudicing such uses. will be protected wherever possible to provide for future development of cycle and pedestrian facilities and to prevent prejudicing future rail freight access to industrial development. (18) (19)
 
  • Improve capacity for additional services at the station and provide additional capacity on the Wolverhampton-Birmingham Stour Valley Line West Coast Mainline (20);
  • Upgrade local services on the Wolverhampton - Shrewsbury Line Upgrade passenger rail services on the lines from Wolverhampton to and beyond Shrewsbury and Walsall (21);
  • Enhance the range and quality of passenger facilities;
  • Improve integration and interchange with other modes of transport.
14.9.15 The Interchange Scheme seeks to address some of these objectives, particularly enhancing passenger facilities and improving integration with other modes of transport. The improvement of the local rail network is an important part of the strategy for encouraging people to use public transport. High quality rail facilities particularly the Rail Station contribute to the image of the City.
14.9.15 The Interchange Scheme seeks to address some of these objectives, particularly enhancing passenger facilities and improving integration with other modes of transport. The improvement of the local rail network is an important part of the strategy for encouraging people to use public transport. High quality rail facilities particularly the Rail Station contribute to the image of the City.
   
Light Rail / Light Rapid Transit
14.9.16 The further development of the Midland Metro is complementary to the Council's strategy for the economic regeneration of the City. Further routes extending the existing Line 1 to better serve the City Centre and to link with other parts of the City are being investigated as part of the wider study being undertaken into the feasibility of extending the Midlands Metro network across the West Midlands. The City Centre Inset Plan shows the proposed alignment for the route in the City Centre and to serve the railway station. It is proposed that the Metro will then be extended to serve New Cross Hospital, Wednesfield and eastwards to Walsall, although an exact route has yet to be defined and will be the subject of consultation in 2003. All Metro proposals will be brought forward through the Local Transport Plan and, where necessary, land required for light rail use will be protected from other development. The statutory process for this will supersede the provisions of the UDP.
   
 
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14.10

Provision for Pedestrians

Policy AM9: Provision for Pedestrians
 
All new developments will be required to provide attractive, direct, safe and convenient routes for pedestrians that integrate with existing pedestrian thoroughfares, desire-lines, public transport facilities, car parks, and other local services. Walking should be given at least equal consideration with the other modes of transport when designing new development and be given greater priority in the City, Town and Local Centres and other areas heavily used by pedestrians e.g. schools.
   
14.10.1 People walking to or within a development site should be able to access all buildings safely and conveniently, without having to cross service areas and car parks. Pedestrian routes through a development site should be clear and obvious and provide good links to the existing pedestrian network and to bus stops and car parks.
   
   
   
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14.10.2 The needs of pedestrians require careful analysis, and should be paramount in development layouts. Key questions that should be addressed are:
 
  • Should priority be given to pedestrians? (22)
  • Do pedestrian routes connect the places where people want to go?
  • Are routes direct, and are crossings easy to use?
  • Are routes attractive, well lit and safe?
  • What is the quality and width of the footway and is it free from obstructions?
  • How easy is it to find and follow a route?
  • Are there surface treatments and signs to guide pedestrians?
14.10.3 The main considerations for a safe and attractive walking environment are:
 
  • People prefer to walk along streets where they are overlooked and can be seen by drivers, residents and other pedestrians.
  • If segregated footpaths are provided they need to be well connected and overlooked by houses and other occupied buildings.
  • Measures that slow traffic help pedestrians feel safer and give priority to pedestrians help them to feel safer and encourage more pedestrian journeys (23).
  • Well-designed shared surfaces avoid conflicts of movement yet encourage other activities to take place.
  • Footpaths should lead where people want to go rather than follow a preconceived geometry.
  • Footpaths in new developments should be positive, direct and barrier-free.
14.10.4 Walking is the link between other modes of transport and a form of transport in its own right representing almost a third of all journeys undertaken. National statistics show that people now walk less as part of their daily routine and that the population is generally leading less active lives. Walking can be an important part of the solution to reduce traffic congestion problems as well as encouraging a more active and healthy lifestyle.
14.10.5 Increasing the number of people on the streets can improve security and help reduce the fear people have of crime and personal security. It is also an important part of promoting public transport use. A poorly lit area along the route or at the bus stops could result in the choice to travel by car or taxi rather than walk or use public transport or could lead to the abandonment of the journey completely.
   
 
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14.11

Provision for Cyclists

Policy AM10: Provision for Cyclists
 
All new development will be required to provide attractive, direct, safe and convenient routes for cyclists that link with the existing or proposed cycle route network, public transport and local services. Developers will also be required to provide secure, covered parking facilities for bicycles, particularly within new housing development and, for large employment development, to provide showers and changing facilities for cyclists.
   
14.11.1 Within new developments cyclists should be provided with clear, direct, and convenient routes. Provision for cycling should be considered as an integral part of the overall site layout including the provision of adequate cycle parking.
   
   
   
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14.11.2 We cycle less in Britain than in many other European Countries, evidence suggests this is not so much due to topography and climate but because cycling appears to be unsafe and inconvenient. Cycle routes and parking are frequently included as an afterthought and are often inconvenient and therefore underused.
14.11.3 The high ownership of bicycles and interest in cycling in the UK mean that there is an enormous potential for increased levels of cycle use. In addition, the majority of journeys are less than 8km (5 miles) in length and a distance considered suitable for travel by bicycle and well within most people's ability. An increase in cycling can make a significant contribution to solving the problems of traffic congestion and improving local accessibility and personal health. There has been significant progress in the development of cycling schemes and traffic management to improve safety for cyclists in Wolverhampton in recent years and all new development should enhance this provision.
14.11.4 Cycle storage space should be provided within new housing developments. Communal, secure cycle storage can make owning and using a bike easier and more attractive. Important factors that need to be addressed to encourage more people to cycle for some journeys include personal safety, secure storage for bicycles, links with public transport and the location and detailed design of new development.
14.11.5 Cycle Parking Standards and 'trip-end' facilities such as secure cycle parking, storage lockers and showers will be included in Supplementary Planning Guidance.
14.11.6 The road-space given to cyclists on the highway and new access to development must ensure that conflict with other road users is prevented. Whilst segregation is required for safety reasons, cyclists should not be isolated from other road users to improve actual and perceived personal security and fear of crime. Although segregation may be required for safety reasons, cyclists should not be completely segregated from other road users as this leads to actual or perceived loss of personal security and safety. Any segregated paths shall have continuity, specifically with regard to side entrances and road junctions. (24) Specific measures for cyclists that may be included within new highway schemes include special surface treatment for cycle paths, advanced stop lines, and priority measures for cyclists at roundabouts, traffic signals and other road junctions and light traffic controlled junctions, and special surface treatment for cycle paths (25). Wherever possible, new routes should link with the wider City cycle network.
   
   
   
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14.12

Park and Ride

Policy AM11: Park and Ride
 
Provision will be made for new park and ride facilities and existing sites protected which serve Wolverhampton and the wider sub region. For Strategic Sites serving the sub-region they should:
a) Be close to major radial routes and located to provide maximum benefits to motorists and public transport provision
b) Be serviced by high quality limited stop bus services Where possible, include secure cycle parking and changing and toilet facilities to allow cyclists to make use of the service (27);
c) Be designed to attain a high standard of community safety as outlined in policy D10 and provided with CCTV and security patrols (26);
d) Provide a high quality environment incorporating extensive landscaping.
Sites to serve a more local need may be smaller and will be considered on their own merits and in accordance with PPG13, the Local Transport Plan and the wider transport strategy.
 
   
14.12.1 Wolverhampton is a sub-regional centre and many people travel into the City for the purposes of work, shopping, education and leisure. The journeys associated with this contribute to the congestion seen on radial routes serving Wolverhampton City Centre during morning and evening peak periods. The provision of high quality park and ride facilities can intercept some of these journeys, reducing the level of congestion. These sites should be close to the main access routes to the City Centre, well signed and well-served by a dedicated or high frequency public transport service. Bus priority measures will be implemented to further support the development of these sites.
14.12.2 A number of sites will be required to serve a more strategic and sub-regional role. These should be located near the main radial routes into Wolverhampton and allow easy access to the rail network either via a new railway station, Midland Metro Stop or via a high quality bus link to the rail network. These will need to be located on the periphery of Wolverhampton or beyond the City boundary and consultation with the Highways Agency regarding their effect on the Trunk Road network will be required (28). A regional study looking at the need for new strategic Park and Ride sites and defining characteristics required for these sites to be successful is currently being conducted. The outcome of this work will influence the Council's policy for the identification and provision of new sites. The regional study looking at the need for new strategic park and ride sites has been completed. This defines the characteristics required for such sites to be successful and identifies some sites to serve the conurbation. One of these sites is at Brinsford to the north-east of Junction 5 of the M54 which lies within South Staffordshire District. Development of such Green Belt sites will only be permitted where non-Green Belt sites have been exhausted in line with the provision of PPG2 as amended by PPG13 Annex E. (29)
   
   
   
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14.13

Car Parking and Servicing Provision

Policy AM12: Parking and Servicing Provision
 
Provision of maximum levels of car parking, minimum levels of disabled car parking and of cycle parking, motorcycle parking and servicing for new developments should be provided in accordance with current Government Guidance, regional guidelines and the Council’s Supplementary Planning Guidance, or any replacement Guidance. Detailed provision should:
a) Comply with the City’s demand management, traffic reduction and car parking policies and targets;
b) Reflect existing and potential availability of alternative modes of travel thereby assisting to increase modal choice; and
c) Address safety and amenity issues in accordance with policies elsewhere in the Plan.
 
Car Parking
The Council will be flexible in the application of parking standards but the following maximum standards should be applied with due regard to PPG 13, in particular to paragraphs 52 to 56 and Annex D. Notwithstanding the application of maximum parking standards, developments will be required to meet their own transportation needs with no detriment to pedestrian safety and the safe and free flow of road traffic. Within the City and Town Centres parking provision should have regard to the advice in PPG 6. Within these Centres non-residential parking should generally be below the maximum standards and provide parking to serve the City or Town Centre as a whole.
 
Land Use Maximum Standards Notes
Residential To be applied with due regard to PPG 3’s aim of a maximum of 1.5 spaces per residential unit across the whole authority. Provision for social housing and for housing for the elderly should reflect lower car ownership rates expected among these social groups. Provision for sheltered housing should take account of any warden or staff parking requirements
- Highly Accessible Locations 1 space per unit plus 0.25 visitor spaces where communal provision Defined as the City and Town Centres and any other location which, in the opinion of the City Council, is highly accessible i.e. within easy walking distance of a railway station, tram stop or high level bus service *
Retail    
- below 1,000 sq m 1 space per 22 sq m  
Food Retail - 1,000 sq m & above 1 space per 14 sq m As per PPG 13 Annex D
Non Food Retail - 1,000 sq m & above 1 space per 20 sq m As per PPG 13 Annex D
Assembly & Leisure (Use Class D2)   Where considered appropriate by the City Council separate coach parking should also be provided
Cinema and Conference Facilities - 1,000 sq m & above 1 space per 5 seats As per PPG 13 Annex D
Stadia ­ 1500 seats & above 1 space per 15 seats As per PPG 13 Annex D
 
   
   
   
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Other D2 uses ­ 1,000 sq m & above 1 space per 22 sq m As per PPG 13 Annex D
Other D2 uses not specified 1 space per 5 seats or 1 space per 10 sq m  
B1 Uses including Offices    
- below 2,500 sq m 1 space per 50 sq m  
- 2,500 sq m & above 1 space per 30 sq m As per PPG 13 Annex D
Higher & Further Education    
- below 2,500 sq m 1 space per 2 staff + 1 space per 5 students  
- 2,500 sq m & above 1 space per 2 staff + 1 space per 15 students As per PPG 13 Annex D
Within the above all figures relate to gross floorspaces.
* As a guide, easy walking distance is generally no more than 400m from a railway station or tram stop or 300m from a bus stop, at an easy gradient and along a direct and well lit route. A high level bus service will generally mean one or more services which together provide access within 15 minutes journey time to the City Centre or a Town Centre. They should generally have a frequency in each direction of six buses or more per hour during peak hours and daytime plus three buses or more per hour during evenings and on Sundays.
 
Disabled Car Parking
All car parks, whether public or private, including those serving residential developments, should make provision for disabled car parking. This should be provided in accordance with the Council’s Supplementary Planning Guidance on Access and Facilities for People with Disabilities, or any replacement Guidance.
This provision should be in addition to any applicable maximum standards and there will be no maximum disabled parking standards. In general, minimum provision should be 5% of capacity on sites up to 200 spaces and 2% plus 6 spaces on sites providing over 200 spaces.
 
Motorcycle Parking
All car parks, whether public or private, including those serving residential developments, should provide secure and convenient parking for motorcycles and other Powered Two Wheelers (PTWs).
This provision should be in addition to car parking. There will be no maximum motorcycle parking standards. In general, provision should be two spaces on sites up to 200 spaces and 2% on sites providing over 200 spaces.
 
Cycle Parking
There will be no maximum cycle parking standards and detailed standards will be published as Supplementary Planning Guidance.
All residential development should provide ground floor storage suitable to provide secure cycle parking for each unit. For housing this may be incorporated within garages or utility rooms, for flatted development in separate secure storage, preferably within the building. Cycle parking will not be required for sheltered housing for the frail elderly but for retirement homes for the active elderly some provision should be considered.
 
   
   
   
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All developments providing employment should provide covered and enclosed cycle parking for staff which is accessible and secure and, on major employment sites, showering and changing facilities.
All developments which will attract visitors, either as customers or in another capacity, should provide covered visitor cycle parking conveniently located and in a position which enables informal surveillance. Such a location will normally be adjacent to a main entrance and can be incorporated in entrance canopies.
 
Servicing and Operational Requirements
Within residential layouts adequate provision should be made for refuse collection, removal vans and delivery vehicles to operate and manoeuvre without obstruction.
Within all non-residential layouts adequate provision should be made for refuse collection and for operational and service vehicles to operate and manoeuvre within the site without obstruction. Servicing of commercial premises from the highway will only be acceptable for small-scale developments where it can be carried out without an adverse affect on safety and the free flow of traffic.
 
Policy AM12: Car Parking Provision
 
Maximum levels of car parking for new developments should be provided in accordance with current Government Guidance (PPG13), Policy H6, Policy CC3 and current Supplementary Planning Guidance. Detailed provision should have regard to the need to:
a) Meet demand management and traffic reduction policies;
b) Provide an increased choice of mode of travel;
c) Accommodate the particular operational requirements of the development;
d) Ensure that car park provision reflects the availability of alternative modes of transport;
e) Make provision for people with disabilities;
f) Address safety and amenity issues in accordance with policies elsewhere in the Plan;
g) Consider National and Regional guidelines on car parking;
h) Meet local objectives and targets for car parking across the City. (30)
 
   
14.13.1 All new Car Parks must make provision for people with disabilities in accordance with the Council's Supplementary Planning Guidance on Access and Facilities for People with Disabilities. In general, provision should be 5% of capacity on sites up to 200 spaces and 2% plus 6 spaces on sites providing over 200 spaces. (30)
14.13.21 Car parks should be designed to maximise vehicle and personal security and have regard to lighting, landscaping and layout. The adoption of "Secured by Design" standards is encouraged wherever possible.
14.13.32 The Council will also encourage the redevelopment of car parks to other uses in appropriate locations such as the City Centre (see Policy CC5), Bilston Town Centre and Wednesfield Village Centre or other centres where redevelopment will be of benefit, where compensatory provision can be made within the new development or where the loss of car parking would not harm the . In other centres, redevelopment to other uses will only be considered where the proposed development is of significant strategic benefit to the centre concerned and the loss of car parking would not harm the vitality and viability of the centre or cause parking problems elsewhere, or where suitable compensatory provision can be made. (31)
   
   
   
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14.13.43 The Council has adopted maximum parking standards as set out in Annex D to PPG13. Particular regard should also be had to parking guidelines set out in PPG3 and PPG6. Policy H6: Design of Housing Development and Policy CC3: City Centre Housing set out specific parking standards for residential developments. Supplementary Planning Guidance will provide further detailed guidance on car parking. PPG13 advises that policies in development plans should set maximum levels of parking for broad classes of development as set out in Policy AM12. The City Council intends, during the lifetime of this plan, to produce detailed Supplementary Planning Guidance on parking standards. (32)
14.13.54 The manner in which car parking is arranged has a fundamental effect on the quality of the development. Vehicles should not be allowed to dominate the space or to inconvenience pedestrians. Parking on the front of a development should be avoided as this detracts from the design of the development, restricts informal surveillance and generally presents an unattractive image.
14.13.65 In residential areas a very careful balance has to be struck between the expectations of car owners, in particular the desire to park as near to their houses as possible, and the need to maintain the character of the overall setting. Where car parking is provided in courts or squares then adjoining buildings should overlook the site.
14.13.76 In commercial developments the best way to alleviate the effect of large parking areas is to ensure that they are designed as an integral part of the landscape treatment and managed communally. This also ensures that pedestrian movement is not determined and restricted by vehicular movement requirements and conflict between pedestrians and vehicles is minimised.
14.13.87 The Council would encourage the redevelopment of any car parks where this is important for the economic (33) regeneration of the City, in particular the City and Town Centres. Alternative compensatory provision of short stay car park spaces may be required to serve the City and Town Centres where this is considered necessary. The shared use of car parks as part of a development will also be considered to serve the wider needs of the City and Town Centres.
   
 
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14.14

Development of Freight Facilities

Policy AM13: Development of Freight Facilities
 
Facilities to aid the movement of freight will be encouraged through:
a) The improvement of the highway to assist the movement of commercial vehicles to employment sites and access to the Strategic Highway Network;
b) Routing of commercial vehicles to prevent any loss of amenity of residents;
c) The assessment, strengthening and renewal programme for bridges and structures to provide for the general introduction of 44 tonne lorries;
d) Where appropriate, the retention of employment development sites adjacent to railway lines for development that requires a rail connection.
e) The protection of redundant rail lines and rail heads where it is considered that they have potential to provide rail freight facilities. (18)
 
   
14.14.1 Improvements to be Strategic Highway Network will aid the movement of commercial vehicles between the City Centre, the main commercial and employment centres of the City and the Regions trunk road and motorway network. There will be an overriding need to protect the amenity of local residents and reduce the impact of freight and commercial traffic on local communities.
   
   
   
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14.14.2 The programme to strengthen bridges and structures to provide for the general introduction of 44 tonne lorries is well advanced but further work is still required particularly on those structures not in the ownership of the City Council. The Council will work with all interested parties to complete this strengthening and renewal programme.
14.14.3 A very small percentage minority of goods are moved by rail and but there is great potential for a change modal shift of freight from road to rail (34). The Council will therefore encourage the construction of new sidings and rail freight facilities where environmental amenity considerations allow and, where appropriate, sites with potential for rail access will be retained for development that requires a rail connection.
   
 
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14.15

Minimising the Effect of Traffic on Communities

Policy AM14: Minimising the Effect of Traffic on Communities
 
In traffic sensitive areas, traffic management and traffic calming will be promoted in order to relieve the adverse effects of traffic on existing residential communities.
   
14.15.1 The Council will continually monitor the harm created by the intrusion of motorised traffic in existing residential areas. Traffic sensitive areas, where the greatest road safety, social and environmental problems are identified, will be prioritised for future improvement. As funding becomes available local residents and interest groups in priority areas will be consulted so that the most appropriate traffic management improvement schemes may be implemented. In designing improvement schemes the needs of emergency services, public transport and cyclists will be considered to ensure their effective and safe operation (35). The Council will continue to work with local schools to minimise the impact of the school run on the local area through measures such as ‘School Travel Plans’ and ‘Safer Routes to School’. (36)
14.15.2 A combination of traffic management measures chosen from the following range will be used in the design of improvement schemes. These will include:-
 
  • Traffic calming
  • Parking restrictions
  • 20 mph speed restriction zones
  • 'Streetscape' design
  • 'Home Zones'
  • Road Closures (37)
   
   
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14.16

Road Safety and Personal Security

Policy AM15: Road Safety and Personal Security
 
All development proposals should be designed and implemented to contribute towards improving road safety and personal security, in accordance with the West Midlands Local Transport Plan objectives and the Road Safety Plan for Wolverhampton.
   
14.16.1 The Government's Road Safety Strategy "Tomorrow's Roads: Safer for Everyone" emphasises that a major improvement in road safety can only be achieved if all agencies involved in road design, building and motor manufacture, traffic regulation and enforcement work in partnership. Wolverhampton has adopted the Government's national targets for casualty reduction by the year 2010 of:
 
  • 40% reduction in the number of people killed or seriously injured in road accidents;
  • 50% reduction in the number of children killed or seriously injured;
  • 10% reduction in the slight casualty rate (expressed per 100 million vehicle kilometres).
  14.16.2 Techniques that will be employed to meet these targets will include engineering, education, training and enforcement in accordance objectives detailed in the Road Safety Plan and the West Midlands Local Transport Plan. The Wolverhampton Road Safety Plan monitors progress towards the National target. The Plan also sets out the programme of safety schemes to be implemented in the City and outlines the education, training and enforcement policies. Local Safety schemes will complement the work on safer routes to school, the policies for walking and cycling, traffic management, and public transport.
14.16.3 All schemes will be subject to a road safety audit in accordance with the Road Safety Act 1988 and guidance contained within the Institute of Highways and Transportation (1996). These aim to avoid the introduction of new safety problems and to identify opportunities to address current safety concerns. Developers will also be expected to adhere to the detailed standards of safety contained within the DETR Design Bulletin number 32 - "Residential Roads and Footpaths" (1992) and its companion guide - "Places, Streets and Movement" (1998) for all residential development proposals.
14.16.4 Wolverhampton Council regards the provision of a safe and secure environment as one of their highest priorities. Actual and perceived safety and security is an important factor in people's choice of mode of transport, particularly their use of public transport or the decision to walk or cycle or indeed whether to travel at all. Child road safety audits, in line with the Government's strategy "Tomorrows Roads - Safer for Everyone", will be undertaken to ensure safety issues are addressed. In addition Safer Routes to School schemes will address safety issues for children and parents on journeys and from school.
   
REASONS FOR PROPOSED CHANGES
1 In response to objections 97/300 & 134/508
2 In response to objection 205/998
3 In response to objection 94/281
4 In response to objections 27/74 & 28/125
5 In response to objection 28/126
6 In response to objection 137/540
7 In response to objection 147/657
8 In response to objection 134/485
9 In response to objection 134/487
   
   
   
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10 In response to objection 94/285
11 In response to objections 122/426 & 177/781
12 In response to objection 177/781
13 In response to objection 150/672
14 In response to objection 150/682
15 In response to objection 150/682
16 In response to objection 134/489
17 In response to objection 153/772
18 In response to objection 138/547 & 138/548
19 In response to objection 153/683
20 In response to objection 134/503
21 In response to objections 84/224 & 134/503
22 In response to objection 27/78
23 In response to objection 27/78
24 In response to objection 94/282
25 In response to objection 153/770
26 In clarification & in response to objection 134/486
27 In response to objection 94/283
28 In response to objection 177/784
29 In response to objection 91/272
30 In response to objections 79/175, 99/311, 118/407, 147/658 & 205/1001
31 In response to objection 196/963
32 In clarification & in response to objections 79/175, 99/311, 118/407, 147/658 & 205/1001
33 In response to objection 196/963
34 In response to objection 138/555
35 In response to objection 134/497
36 In response to objection 144/609
   
   
   
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37 In response to objections 28/124 & 144/609
   
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