Comment

Draft Black Country Plan

Representation ID: 18899

Received: 25/09/2021

Respondent: Mr Richard Carter

Representation Summary:

Over the years, local and national newspapers have been full of stories about urban and town/ city decline. Latterly, these stories have been replaced by a constant string of articles about urban and town centre regeneration project. More recently, however, regeneration articles have been followed by descriptions of town centre regeneration projects that have failed quite dismally - but why should this be? If so much time, effort and money has been spent on a project, why would
any regeneration project fail? The answer to those questions is quite simple: lack of foresight and
poor project planning.
If a regeneration project is to have any chance of success, the first stage of any project must be to understand why the decline occurred in the first place. If the causes of decline are not identified, it is highly likely a project will fail primarily because the causes of the decline still exist - and St Austell in Cornwall, provides an ideal research subject. Not only did St Austell town centre see progressive and avoidable decline over the years, the regeneration project, that made so many promises, failed to satisfy any of them. Consequently, attempts to regenerate the town are still ongoing.

Personal Note:
When the St Austell town centre proposals were first published, I saw straight away that, in all probability, the project would fail primarily because it wasn't attractive, it didn't provide the level of retail space required by many businesses and it didn't offer any advantages over other, already established town I city centres. At the time, I was personally ridiculed for being negative and for not considering the benefits the project would bring. Time and a failed town centre regeneration project have proved me right - although those that derided me will not admit it.

At this point, it is worth identifying that St Austell isn't the only town that has suffered from regeneration failure. The following links identify other urban and town regeneration failures or concerns:
• https://www.london.gov.uk/questions/2019/19701
• https://www.tandfonline.com/doi/abs/10.1080/00343400220137173
• https://www.taxpayersalliance.com/the failure of regeneration schemes
• https://cles.org.uk/publications/urbanregeneration-success-or-faiIure/
• https://www.pbctoday.co.uk/news/planning-construction-news/urban•
regeneration/43468/
• https://petition.parliament.uk/archived/petitions/73580
• https://g eographyfieldwork.com/u rban regeneration issuesU Kcities. htm
So what are the reasons for town centre decline? In short, the main answer is poor planning decisions and lack of vision, e.g.:
• Loss of industry and employment.
• The building of out-of-town retail centres resulting in a much lower town centre footfall.
• Large supermarket chains increasing their range of sales good in direct competition to those sold by local shops, e.g. clothes, records, books.
• Supermarkets being allowed to trade unfairly. The latter stages of Covid lockdown is a prime example of this. Although individual, small shops were not allowed to open, supermarkets being allowed to sell the products that the smaller shops sell, e.g. clothes, shoes, stationery etc.
• Councils charging for parking when retail parks provided free parking for (say) 3 hours.
• Poor transport connections.
• High business overheads, e.g. rental and business taxes.
• Poor investment.
• Changing building use from employment to housing.
Having identified why the town centres decline, there is a need to establish why regeneration projects fail:
• There is no room for expansion because town centres have become hemmed in by housing etc.
• Designs are not attractive; they do not entice visitors and, therefore, they do not increase footfall.
• Designs, and the retail outlets provide, are no different from many other town centres. As above, they do not entice visitors.
• Designs do not provide the retail space required by many large businesses.
• Designs do not provide flexible, resizable retail space.
• The range of retail outlets is too small and/ or they do not provide what customers want.
• Regeneration isn't backed up by increased employment and self-esteem.
• Transport links and parking facilities are not improved.

Fully-factored Urban Regeneration:

Having identified the causes of decline; and this requires total honesty on the part of all stakeholders and, in particular, the local authorities, a fully factored, realistic and "common sense" based regeneration project needs to be initiated.
In many cases, as has been identified in the case of Salford (geographyfieldwork.com above), the "bottom line (for any regeneration project) is providing work". Until this issue and the associated issue of poverty have been resolved, there is little point in starting anything else.
In addition to employment and poverty, as a minimum, fully-factored regeneration projects will need to consider (see also Housing):
• Making better use of available brown field sites and waste land. Currently, such sites are being under-utilised by ill-conceived housing and industrial developments. For example, in the picture to the right, this housing
development located west of Bilston town centre could have housed at least four times the number of families in low rise accommodation and increased the openness of the estate at the same time by providing more communal spaces.
• Maximising the available town centre land; especially land that is derelict, or that houses derelict or
semi-derelict properties and car parks.
• Reversing previous planning decisions that have resulted in increased road use and congestion.
• District heating provision.
• Public transport services and connections.
• Centralised Health Care services.
• Hotels and other holiday accommodation.
• Schools, library and sports facilities (consider combining use of school fields etc in order to maximise use). Sports facilities would be multi-functional, i.e., they would be flexible enough to be able to host a wide variety of sports, business and entertainment events. Equally, they would have fully size facilities so that, for example, there would be no need to build the additional stadia required by the Olympics.
• Centralising and locating industrial sites close to district heating plants so that waste heat can be collected and fed into the main system. Alternatively, either by retro-fit or including this requirement in all future designs, all industrial units should be fitted with heat exchangers and roof-mounted air source heat pumps so that all waste heat, including heat output from computer rooms etc, can be gathered and fed into local district heating booster stations. Equally, photovoltaic technology should form part of the roof structure. From the picture on the previous page, it can also be seen that energy generation opportunities are being missed.
• The accumulation of pockets of land into open spaces and managed woodland.
• Ensuring that all new developments match the character, feel and history of the local community- unless there is a specific reason not to. Many people lament the loss of old buildings, many of which have been replaced by roads or modern, characterless buildings. Facebook's "Wolverhampton in old photographs" provides many examples of comments that are pertinent to this statement.
• Ensuring that rest stop, overnight parking and ease of movement provision is made for long distance lorry drivers. Ideally, lorries and utility vehicles should have alternative ways of accessing town centres etc to facilitate deliveries. Although it is recognised that Helsinki, Finland benefits from underlying bed rock, the following Youtube video provides an
example of how the Finns evolve their infrastructure for everyone's benefit:
https://www.youtube.com/watch?v=ELSnrlOoFHE (watch from 7:40)

Town Centre Regeneration:

Here again, there is scope for major improvement. Forming part of urban regeneration projects, in addition they will consider:
• Ensuring that all loading bays, car parks, public transport interchanges and other facilities are located at basement or sub-street level.
• Buildings can accommodate the facilities required by major retailers.
• Open spaces are included.
• Road provision is kept to an absolute minimum. Carefully designed car parking will reduce the need for roads.

The following links provide examples of the kind of space savings that can be achieved if the desire is there.
https://www.myhelsinki.fi/en/see-and-do/underground-helsinki https://www.g-park.com/showcases/newsitem/10034/stockmann-helsinki Bilston:
It is known that the WMCA has plans to regenerate Bilston town centre (see the link below). Although this project is welcomed, using a piecemeal approach; such as is being suggested in the article, will only limit what could actually be achieved (and, beside, far more than 500 homes could have been delivered in the Bilston Urban Village).
https://wmgrowth.com/article/derelict-pipe-hall-site-to-be-redeveloped-as-wmca-accelerates•
regeneration-in-bilston-and-other-town-centres
The Pipe Hall mentioned in the article is located to the extreme right of the highlighted area in photograph below. As can be seen, it is surrounded by derelict and semi-derelict land which will also form part of regeneration process. However, it needs to be identified that the provision of housing {Pipe Hall and the old Royal Mail Office site), does not constitute town centre regeneration, i.e. it does nothing to attract people to the town from elsewhere.
project that would include district heating provision. Essentially, at the top of the area, other than a few shops, a doctor's surgery and a public house (which could be retained, the area contains Bilston Market (building and open area and the bus station (which was opened in1991) and the Metro line (located between the Pipe Hall building and the bus station).
Bilston Market could be moved to new, multi-story accommodation that would utilise the Pipe Hall site and surrounding land and the area over the Metro line, i.e. the Metro station would be underground. The Market building, externally, would be Victorian or Georgian in appearance and, internally, would be designed to attract visitors, i.e. it would be elegant rather than purely utilitarian.
The photographs to the right and below show what could be achieved. They are of Van ha Kauppahali (Old Market Hall) in Helsinki. This building attracts visitors to it so, consequently, the market traders benefit from increased footfall.
[See attachment for images]

Once the market has been moved, the freed space could then be used to develop the low-rise facilities that are listed above. The design of these buildings would also reflect Bilston's heritage (see the front elevation design under Housing). Further space could be gained by placing the bus station and car park facilities underground. The underground bus station would be directly linked to the Metro station and could, conceivably, be located directly below the existing bus station.