Comment

Representation ID: 22558

Received: 06/10/2021

Respondent: DNA Investment Holdings Ltd

Agent: Lavata Group Ltd

Policy CSP2 – The Strategic Centres and Core Regeneration Areas

We are in agreement that the Strategic Centres and Core Regeneration Areas of each of the Local Authorities in the Black Country should be the focus of regeneration. The Client’s aspirations for the Site are in alignment with the aspirations of the Strategic Centres as set out in part 4 of the policy as the site will be able to provide much needed housing, built at a high density in the Walsall Town centre boundary. The site is seeking to provide only housing on the site due to the location outside of the
core commercial areas, but the policy itself makes it clear that not ALL development must be mixed use, just the majority. It is therefore recognised that not all development in the Strategic Centres is suitable for mixed use development subject to individual site locations/constraints. The Site also benefits from being within easy walking distance from Walsall Railway Station, the Bus Station as well as access to the Mayors Cycle scheme. The development of the Site also provides the opportunity for the existing green infrastructure surrounding the Grade II*Listed Church and the Walsall Memorial Gardens to be utilised more efficiently. It should be noted that the Memorial Gardens have been closed for a number of years, so members of the public who are aware its presence, have not been able to use these as they should. Development of our Site will allow an opportunity to look at options to open up the gardens again and create a critical mass of people/population who would be able to access and use the gardens on a daily basis.

To the south of the site lies Parkers Green Park, which is a steeply sloping green space. There are no play facilities on the site due to its gradient, however forms part of the open green spaces/infrastructure for this part of Walsall and the town centre. It is not clear how well this space is used by the public or local residents, but the addition of housing in this area will help with the provision and usage of the infrastructure.

It is unclear why the Site has not been bought forward as a housing allocation, given that it forms a secondary (now primary given the current BCCS is now halfway through its adopted time period) site for employment land release in the adopted Walsall Town Centre AAP. It is clear that the DBCP has not actually looked any sites in the adopted AAP to see whether they are still able to come forward.

This is a fundamental flaw in the DBCP as the NPPF is clear Green Belt release should be a last resort once there are no sites in the urban environment. There is no reference to when the AAP’s will be updated if at all and how these will fit in with the DBCP. This is incredibly important as the DBCP is relying on the AAPs to help deliver the level of housing sought in the Strategic Centres. The AAPs should be updated as part of the current DBCP in order for these to provide the details missing from the Local Plan and provide the local direction of growth including allocations for housing for the Strategic Centres, taking into account physical typography and constraints.