Policy CEN6: Meeting Local Needs for Shopping and Services

Note: questions numbers are those in the full strategy document.
Question 2 Evidence
Housing
The Housing studies do not seem to adequately examine migration flows. In considering options for addressing any shortfall in housing supply, it would be helpful to have information on flows of migrants between the study area, Birmingham and other parts of the former west Midlands region. The Black Country receives many migrants from Birmingham but exports people to other areas including Telford and Shropshire. Thus there are important links to areas outside of the HMA. The EDNA contains useful analysis of commuting flows. indicating the wider area to which the Black Country relates.
The analysis should examine the age composition of different migration flows. Previous studies indicated that people moving from the Black Country into nearby areas tended to have higher proportions of families with children and be from higher paid backgrounds. Understanding of these flows will help to plan for house types and supporting facilities and transport that will be required if more development is needed in the Green Belt and beyond.
Much of the projected housing growth stems from net international migration; this is reflected directly in the ONS projections for the Black Country and also indirectly in the projected migration flows from Birmingham. This is a topic of great uncertainty. Flows since 2014 have been higher than in the ONS projections, but post-Brexit policies may reduce flows greatly. Given the scale of growth envisaged, some assessment of the range of uncertainty is required by sound planning.
Transport
The collection of evidence on traffic impacts should not just focus on peak flows into the major centres, given the dispersed pattern of employment across the Black Country and the increase in traffic associated with the school run. Traffic congestion is apparent through many parts of the Black Country and for longer periods of the day than in the past. Delays and pollution as key junctions should be monitored.
If new peripheral housing is proposed then the impacts on the whole network should be considered, not just in the vicinity of the proposed developments, as residents in existing built-up areas already
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suffer the effects of increasing congestion. Many residents of new developments will travel back into the Black Country and Birmingham for work and other purposes. For example, do you have any data on the effects of the development on the former Baggeridge site on peak flows on the already congested routes between Gospel End, Sedgley and into the Black Country?
Health
The effects of traffic and congestion and proximity to existing polluting industries health should also be examined.
Question 3: Housing Need
At this stage I would not wish to offer an opinion on methodology in relation to Government guidance. My view is that Government's requirements for methodology are flawed; it remains to be seen if the new standard method improves the situation.
The scale of housing need is very large but it is wise to have a strategy for the projected growth as this may be required in the longer term even if the projections are too high. However, I have two reservations about planning for this level of growth under current planning rules, which are naive, deterministic and inflexible.
Firstly, my experience as a user and producer of demographic, housing and employment information has shown the severe limitations of knowledge and the difficulties of forecasting the future with any precision or certainty. As to economic forecasts, it seems that even at national level, these amount to little more than guesswork even in the short-term. Forecasts can easily be revised, and often have been, and even information about past trends is recast (e.g. after the 2011 Census) . Long-term development decisions are not that easily undone, and the real impacts can be very large and enduring. The estimation of housing 'need' and the adoption of policies to meet that need should ideally be based on weighing evidence, taking account of its quality and reliability, against real impacts on the ground, together with an understanding of risks.
Secondly, a sensible planning system would provide long-term direction with flexibility and phasing to reflect changes in demographic trends and economic conditions. However, current planning rules are deterministic and inflexible. My concern with policies to meet the large projected housing growth is whether and how the release of a vast amount of greenfield land can be controlled without jeopardising the regeneration of the core Black Country. The focus on new development can lead to a failure to consider the implications for the economic, social and environmental interests and needs of most Black Country residents. Once Green Belt land is made available, it will be developed first unless strong phasing policies can be put in place.
Question 4. Employment Land Requirements
It is very important to allow scope for major employment developments. The i54 site is a good example of the benefits of long-term planning. That said, the amount of land proposed seems large in relation to what is likely to be achieved. My concern is that much land originally identified for industry or offices in the past has gone for some form of retail or more recently distribution: valuable land close to Motorway junctions has gone for retail or logistics. These uses are important but generate lots of traffic on strategic routes and provide jobs that are either low-paid or don't
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contribute much to the local economy. This may simply happen again if too much land is identified for industrial or office use.
I am also concerned about the seeming reluctance to tackle the undesirable legacy of the Black Country's long mining and industrial past (paragraph 3.9). This area's long and complex industrial history has left a juxtaposition of dirty, low value uses close to housing. Unless this is addressed, the area will not attract higher income residents, whose spending is vital to improving the local economy and its shopping and cultural facilities. Queen Victoria is supposed to have drawn the curtains as her train travelled between Brum and Wolverhampton; the view today is not so bad but the image that is presented to the millions who traverse the motorway, rail and canal routes through our area is far from appealing.
Other businesses thrive but are now badly located, making them less efficient and often generating traffic and environmental problems for local residents. I live near an oil-mixing plant that brings in tankers from across Europe. Unfortunately it is close to housing, quite noisy at night and a source of traffic congestion as the access is poor. It is also in a key canal-side location which could be an environmental and economic asset, being close to the major museums of the Black Country.
Given the amount of land that is being set aside for employment, it is important that a proportion is set aside for businesses that should relocate. This will include areas for 'dirty' uses.
Key Issue 5: Green Belt Review
If the required amount of development cannot be accommodated within the existing built up area, then some Green Belt Land will be needed. However, such a review should be undertaken as part of a wider investigation of options as peripheral development may not be the most desirable in terms of environment, sustainability and the well-being of the population.
The investigation should be wider in terms of
 geography - involving councils in Shropshire, Staffordshire and Worcestershire, as well as those in the Grater Birmingham HMA
 history - being informed by lessons from the past about new and expanded towns and peripheral developments on the edge of the conurbation.
 full impacts - not only on the immediate localities but also on the wider conurbation, for example through increased traffic flows back into employment and shopping areas.
 the proper role and value of the Green Belt - We live in the heart of the Black Country, but Green Belt allows us access to open countryside within about two miles of our house. It provides a breathing space, somewhere to walk and a visual relief from the congested and busy metropolitan area. Green Belt development would not affect my immediate living environment but it would make living where I am less desirable.
Question 6 Key Issues
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Transport (or keeping the Black Country Connected).
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This fails to properly acknowledge the widespread problems of existing traffic congestion within the Black Country and on the national motorway routes. HS2 offer opportunities but also threats to the Black Country's rail connectivity. Congestion, coupled with the still poor environment in many areas is a barrier to building a more prosperous and liveable Black Country.
The plan needs to be informed by the Transport Strategy, but the large amounts of development will require the Transport Strategy to change. The scale of development envisaged will have major impacts on traffic flows across the whole area. It should not be assumed that the proposals in the Transport Strategy are all that will be required. The horse pulls the cart but the driver should be in charge of both.
Economy. The same point as for transport. The relationship with the economic strategy should be two-way. Planning is about balancing competing priorities. The economy, and aspirational economic strategies, can change rapidly - will the Midlands Engine still be working in 5 years time? The impacts of development and changes in the environment are more enduring.
Question7: Vision and principles
Agree that these values remain appropriate.
Question8: Spatial Objectives
1. Major centres. Trends in retailing and services have changed rapidly with the increased use of internet and direct delivery of goods and the decline in local banking and other public and commercial premise-based services. These add to the long-term challenges that have afflicted centres over previous decades. It is necessary to reappraise their role perhaps looking to increasing residential and leisure uses.
2. Employment is key but the emphasis on logistics may need to be reviewed and increased attention paid to innovative manufacturing. HGV drivers report and call at West Midlands' depots but they may live far away; manufacturing can provide well-paid jobs for local people.
8. Should include educational facilities at all levels. Sustain role of the universities and allow for expansion of schools to meet the growing child population ( a 26,000 increase 2014-2039 according to ONS).
9 and 10. Significant stocks of re-usable minerals and construction material will continue to become available through redevelopment of older sites. The recovery of this and conversion into new products or energy should take place within the Black Country, subject to environmental and health standards.
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Question 11
Neither, but 1B preferable. The strategies should commit to exploring sustainable options beyond the Green Belt as part of a major strategic review across a broader geography.
Release of existing employment sites: improve local amenity for nearby residents; do they suffer poor location and access in relation to nature and amount of vehicle movements; vacant for a long period; appearance.
Question 12A.
Some 'rounding off' may be acceptable but not supported as a major contributor to needs. This is a soft option, which is easiest to deliver for authorities and builders, but very unsatisfactory. Developers will build these sites first, unless strict phasing is imposed, and this will undermine regeneration and the more sustainable options.
Internal wedges can be very valuable in providing access to open space for a large number of residents. If land is released in this way, developments must be required to provide a substantial amount of accessible open space and footpaths to maintain and improve local amenity.
The cumulative wider impact on services and traffic locally and across a wider area would be large but would be difficult to relate to any specific development. This would create problems in securing developer contributions.
In reviewing the peripheral boundaries it is vital to consider the visual impact on the perception of sprawl and separation between settlements. The mere physical distance between built-up areas is not the sole criterion for assessing boundaries. In some cases it may be possible to allow expansion if new development is shielded by woodland etc. In other cases a proposed development might leave a physical gap, but through placement (e.g. on a ridge) may erode the perception of separation.
Question 13a
If Green Belt land is needed then this option could satisfy that need in part. Strategic infrastructure (transport) should be specified as should the employment content. Ideally should make provision for affordable housing, most realistically through shared ownership. Peripheral development in the Green Belt raises the same issues as mentioned in Question 15c and these should be assessed when considering such development.
This option should be assessed in parallel with consideration of sustainable developments outside the Black Country Green Belt - see question 15.
Question 14 The Black Country has large areas of low density housing developed during the period 1920-1950s and includes Social Housing, ex- Council housing bought through Right-to-Buy and privately built estates. Much of the housing is sound, but will deteriorate without maintenance and investment. Many owners struggle to maintain their properties and their often large gardens.
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Ultimately this issue will need to be addressed, possibly through redevelopment; the diversity of tenures will be a challenge. Selective redevelopment would offer the opportunity to improve housing conditions, save energy and increase densities. It may also allow the development of 'aspirational' housing for higher income householders. The viability and contribution of such redevelopment should be explored before large areas of greenfield land are developed.
Questions 15 The scope for 'exporting' growth to other sustainable locations beyond the Green Belt should be explored in parallel with the Green Belt Review to ensure that the most sustainable options are identified. However, the search should extend beyond the Greater Birmingham HMA as the Black Country relates strongly to areas in Staffs, Shropshire and Worcestershire.
In relation to question 15c, many rural areas face challenges in labour supply as their population ages; new housing can help and also take up spare capacity in schools etc. This may reduce the impacts on commuting of spreading development further. However, it may be necessary to also divert some employment development also to these areas, to avoid generating additional in-commuting.
A new settlement should be considered as part of this approach. To be viable and provide a good range of facilities it should aim for an eventual size roughly the same as Codsall, Penkridge or Wombourne. A possible location would be in a triangle north of the M54 and west of the M6. This is close to the Jaguar development and could be linked to regeneration and transport improvements, with Park and Ride, along the A449 into Wolverhampton
Questions 16-20 The strategy should provide a mix of locations to meet a diverse range of needs, so the preferred option should be a mix of the options.
Question 24 At a personal level we became aware of the pressure on local school places when we investigated moving our grandson and his mother into the Black Country; no primary places were available within reasonable travelling distance. A new local school has recently been built on a sports ground; this will create traffic problems on an already congested route. It is important that the plan identifies the amount of land needed for new facilities, such as schools, and specifies requirements in terms of access and parking. It may be easier to provide facilities in association with larger new housing developments, in which case housing mix should be designed for families with children.
Question 25 In considering peripheral developments, it will be important to consider any deficiencies in social etc provision within existing adjoining areas. In this way, new development can be 'sold' to existing residents affected by new developments.
Questions 26 and 27.
New developments offer the chance for micro-generation and efficiency in energy use. Guidance should be prepared to ensure that developments are designed with energy efficiency in mind.
Question 27 Paragraph 5.12 is incorrect in implying the current transport situation is satisfactory. The motorways are struggling, and any disruption, such as the current strengthening of the M5 viaducts, creates major problems for long-distance and local travellers. Traffic on local roads has grown greatly in the 10 years since I have lived here. The peak now extends from about 3.30pm to
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nearing 7pm. Only yesterday i had to travel from Tipton to Sedgely at 1615; a 2.5 mile journey too 25 minutes! Local roads can be near to gridlock at peak times.
Industrial traffic mingles with local traffic to the detriment of both. There are clear benefits to be had by providing sites closer to main roads, so that firms to can relocate while staying within the area.
The Birmingham-Wolverhampton railway runs at capacity and offers little opportunity to increase the frequency of services, particularly serving local stations.
Walking and cycling need to be encouraged but this be requires safe and convenient routes? I can cycle to the station in 4 minutes and walk in 10, but to do so I have to crossing several roads, only one of which is safe to cross.
The metro extension to Brierley Hill will be welcome but the area needs to follow the lead set by Greater Manchester and develop a proper network: for example extending south to Stourbridge Junction.
Question 30.
A thorny question! One approach might be to use affordability contributions from Green Belt sites to fund affordable housing in the built-up area. This might prove attractive to developers, but might also exacerbate social polarisation. Evidence on wider traffic impacts of peripheral developments might be used as a leaver for contributions to improvements on key transport corridors. In reality only a restrictive policy on greenfield development will secure urban regeneration.
Question 32.
Support the idea of HIAs
Question 33
Policies to improve the environment in existing built-up areas should take account of health benefits. Policies to address lifestyle-related problems should be addressed through policies that make walking and cycling more attractive. More restrictive policies on fast-food outlets are needed, although this is a bit late given the proliferation of existing outlets.
Question 34a.
Yes. The impact of new developments on existing residents should also be considered as part of the strategic review. Often the impacts of a new development are felt away from the site - most obviously through increased traffic on already congested roads. It would be useful also to have health impact assessments for those existing areas where there are likely environmental factors, pollution, noise, air quality issues.
Question 38
If Green Belt developments cannot meet existing accessibility requirements can they be regarded as sustainable? Peripheral development will generate more car travel and longer distances. If a
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development cannot reach the standards set, would it be possible to require offset contributions to improve accessibility and public transport elsewhere (e.g. in adjoining built-up areas)?
Question 47
Yes. If it is necessary to develop Green Belt for housing then this policy should aim to recoup some of the higher development values realised for enhanced contribution to services. It important that new developments set aside sufficient land for provision of schools and the like. Greenfield sites are likely to appeal to those setting up free schools. Unfortunately this is socially divisive, but it may necessary to ensure that enough school places are provided.
Question 49
The policy on release of existing employment land should protect existing businesses and viable enterprises, but should also identify major sites that could be redeveloped for housing or other uses. It should also include criteria for assessing windfall redevelopments that cover the amenity of local residents and any existing traffic and parking problems. An adequate selection of sites suitable for relocating businesses should be identified.
Question 55
Policy should be retained/enhanced.
Question 56
It is not clear whether the list includes the Dudley Canal Portal. It should as there is a for improvements to the highway, public transport and pedestrian access to and from the site.
Consideration should be given to including the former Chance's glassworks given its key position alongside the canal, motorway and railway routes through the Black Country, and the recent formation of a Trust aiming to secure restoration.
It is important that all developments close to and adjoining the canals should enhance this important network of routes and attractions, improving access where appropriate. Opportunities to provide facilities for boat users should be encouraged as should the provision of shops, cafes and other services for boat users and those visiting the canals.
Questions 58-61 and 82
The relevance of policies for many of the district and local centres is open to question. Many smaller centres are dominated by fast-food outlets, It is also time to reassess the boundaries of some.
There may be a need to review policy criteria that apply to the new breed of medium size supermarkets (e.g. ADLI, LIDL) which are springing up in other locations (e.g. the Priory in Dudley). Not sure of the size of these in relation to thresholds for out-of-centre developments (covered by CEN6 and 7) referred to in paragraphs 6.1.11-13.
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Questions 69-73
There is a need to consider some conversion/redevelopment for housing within centres, even if this reduces retail floorspace. New housing can help to support, and lead to development, of a wider range of convenience shops - as in Birmingham centre.
Question 72
As above. Vacancy rates in all centres, large and small have remained high for many years. It is now time to accept reality. It must be remembered that in some older centres, what were once houses were turned into shops. It may be time to reverse the process.
Question 79 Need a restrictive policy on fast-food outlets in residential areas.
Question 86 Is there a policy covering the loss of public houses to other uses?
Question 88. Transport priorities will need to be reassessed in conjunction with the development of the strategic locations for housing and employment growth. As a resident, my view is that the area has major transport problems which can only be met by a much more ambitious programme for modal shift plus selective road improvements.
Connectivity to HS2 will be a major issue presenting opportunities and threats. HS1 has had mixed impacts in different parts of Kent, massively improving access for towns that are on the HS network, while adversely affecting the cost and quality of train services for many other areas.
Question 92
Support the concept of a coherent walking and cycling strategy, but reserve judgment on content of existing strategy. The canal network provides the most strategic long-distance routes, but unfortunately much of it is poor quality. Suggest you visit Sheffield/Rotherham to look at the River Don cycleway, or perhaps Leicester for cycle routes along former railways.
It is important that major new developments contain adequate facilities for cyclists and pedestrians, and where possible provide through routes that can create a longer route. Too many recent developments (e.g. Castlegate in Dudley) are bike/pedestrian unfriendly). In other cases opportunities to create new routes have been lost: e.g. the swimming pool and adjoining hew housing estates on Alexandra Road/Church Lane Tipton.