8 The Black Country Centres

Comment

Representation ID: 11032

Received: 20/09/2021

Respondent: Mr John Griffiths

I don't believe enough emphasis has been placed on how town centres will collapse following the growth of on-line shopping and the effects of Covid. There will be lots more brownfield sites available during the next few years and unless we can use them effectively there will be a dead canker at the heart of every Black Country town.

Comment

Representation ID: 11763

Received: 08/10/2021

Respondent: Mr John Hemming

The black country centres are becoming obsolete , consideration for the state of high streets and town centres in 20 years time needs to be considered carefully

Object

Representation ID: 11833

Received: 09/10/2021

Respondent: Mr Richard Knight

Black Country centres should also include housing as a primary provision. This ensures the centres do not become 'ghost towns' at night and will help address the change in shopping and travel habits due to the increase in ecommerce and the pandemic.

Object

Representation ID: 12065

Received: 10/10/2021

Respondent: Miss Angela McCracken

In the Walsall area, adding housing on green belt land I.e. close to Walsall Arboretum will have a detrimental effect on local residents.

Object

Representation ID: 12253

Received: 11/10/2021

Respondent: J A Wilcox

This is effectively joining two very different settlements - Pheasey and Streetly, with hitherto undisclosed effects on postcodes, political constituencies (currently held by two different parties) and appears against the very point of the Green Belt, not mentioning the effect on wildlife and green spaces.

Comment

Representation ID: 13223

Received: 08/10/2021

Respondent: Mrs Angela Wadeley

Concerning our Town Centres I feel there is little that any of the boroughs can do to bring their major town centres back to their former glory days of probably 40 years ago. Those
days of big high street stores have long gone, initially with the opening of big retail parks like The Merry Hill Centre, more recently because of the move to online shopping and the demise of the big brands like Debenhams, the Philip Green Empire, etc. Dudley Town appears to be
relying on its' historic idea but although some buildings have already been improved it is a
poor shopping experience despite putting money into it. I can't see this changing. I wonder how disappointed tourists are in the High Street when they venture outside the Castle, Black Country Museum and Canal Trust. At least the owners of The Station Hotel are currently trying to make a destination of note. Linking Brierley Hill to Merry Hill, particularly if the Metro finally gets there has merit but again I believe only the old locals will use their old town centres.

Comment

Representation ID: 14479

Received: 11/10/2021

Respondent: John Rowley

Since compilation of the draft Plan began our high streets have emptied of shops, office blocks have emptied of staff. The Covid-19 pandemic has also accelerated public recognition of the benefits of clean air and green spaces. The Black Country Plan needs to be more radical to deal with these changes.
Conversion of city centre shops and offices to accommodation, cultural and leisure use must be encouraged. The challenge of climate change will encourage local shopping centres at the expense of the city centre. The challenge to reduce traffic pollution may encourage working from home. For these and many other reasons green spaces are likely to be invaluable for the immediate future.

Comment

Representation ID: 18246

Received: 09/10/2021

Respondent: Valerie Morgan

There are so many derelict pubs and business premises which surely need demolition. Our city centre is becoming a laughing stock because of the amount of abandoned buildings and eyesores. The UTC site has become famous for its development and careful use. Can we not learn from that?
Rebuild our city. Let people live there, near their jobs and colleges, needing less transport to get them there. It means that safety in the city increases. The more people living there, the more presence of inhabitants, the less crime there will be. I totally support the use of our city for housing around local shops. We need the economy to be rebuilt in town. City living is to be encouraged as opposed to removal of wildlife.

Comment

Representation ID: 18899

Received: 25/09/2021

Respondent: Mr Richard Carter

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.

Comment

Representation ID: 19290

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

Introduction
Comment: The implicit acknowledgment given in the Black Country Centres introduction and policies regarding changes to retail and the significance this has for the future of these centres should be made explicit. Ongoing reductions in the number of occupied retail and office spaces provides the opportunity - as implied in the BCP - to strategically plan vibrant and desirable leisure and residential centres which support the growth of the Black Country economy. This section of the BCP should more strongly set the scene for the review of the four Strategic Centres Area Action Plans with an ambitious vision for this future.

Comment: The reimagining of Strategic Centres as desirable leisure and residential centres will reduce pressure for these land uses elsewhere. To fully realise this ambitious vision, however, significant planning and investment must be given to green and blue infrastructure. The value of well-planned green and blue infrastructure with regards the services it provides in mitigating the impacts of climate change (e.g. urban heating, pollution and flooding) and the substantial increases in desirability this provides should be made clear. Furthermore, it should be set out in the BCP that this will be a requirement of the review of relevant Area Action Plans.

Comment

Representation ID: 44924

Received: 11/10/2021

Respondent: Aldi Stores Ltd C/o Turley

Agent: Aldi Stores Ltd C/o Turley

Comment on the retail policy evidence base:

We note that the consultation process does not invite comment on the supporting evidence base for the emerging Black Country Plan. However, we have concerns about certain aspects of the retail policy evidence base which we consider need to be aired on the basis that the proposed retail policies are directly influenced by the outputs of the Black Country Centres Study (BCCS). We therefore set out our comments below:
Introduction
1. The BCCS seeks to assess the quantitative need for new retail floorspace over the period to 2039 within a geographical area consisting of four LPA areas and containing a population of over 1 million. It is therefore one of the largest, most extensive retail studies of its kind across the UK. Its findings are underpinned by a household shopping survey which sought information on shopping patterns (convenience and comparison goods) from a representative sample of 5,500 households living across the Black Country. The assessment can therefore be fairly characterised as a strategic and high level.
Absence of Qualitative Evidence
2. The BCCS also presents a quantitative assessment of retail needs only, with no analysis of qualitative factors such as, in relation to convenience retail development, the extent to which existing retail facilities are able to meet the needs of existing populations that use them. This qualitative assessment would normally include analysis of such factors as:
• the quality and choice of foodstore provision within different centres or zones;
• whether existing stores are overtrading or undertrading relative to company average turnovers (and if overtrading, the extent to which that undermines store performance); and
• the adequacy of car parking provision for shoppers carrying out a main food shop.
3. There are no questions in the household survey which seek to capture views on the adequacy of the existing retail provision within the BCP area from a qualitative perspective. For retail studies covering a smaller geographical area with a relatively small catchment population, the inclusion of questions within the household shopping survey to elicit data on the qualitative aspects of retail need is standard practice.
4. While the reasons for not delving into such a detailed level of analysis for a retail study covering the whole of the Black Country is understandable, it must be recognised that the study can necessarily only provide an overview of the quantitative retail floorspace needs of that area. Moreover, because there is no recognition in the Study of existing foodstore overtrading, it effectively underestimates the quantitative need for new convenience retail floorspace. This is potentially the case within the Study area as a whole, but almost certainly the case at a local level within the constituent local authority areas. For example, we have evidence to demonstrate that existing convenience provision in three of the four main centres in Walsall (Bloxwich, Brownhills and Aldridge) is trading at levels substantially in excess of company averages for the individual stores within those centres. This gives rise to some of the negative qualitative impacts associated with overtrading such as car parking congestion, crowded shopping aisles and difficulties in terms of restocking.
5. Confirmation that the methodology adopted in the BCCS to assess quantitative need does not include any assessment of overtrading in existing retail stock is set out at para 5.4 of the Vol 1: Main Report (2021 Update). This states that:
“It has necessarily been assumed for the purpose of the capacity assessment that the BCLA’s (convenience and comparison goods) retail market is in ‘equilibrium’ at the base year. In other words we assume that existing centres and stores are broadly trading in line with appropriate ‘benchmark’ turnover levels at the base year and based on adjusted market shares for new store openings. Therefore, any residual expenditure available to support new retail floorspace within the study area over the development plan period is derived from the difference between the forecast growth in ‘current’ (survey-derived) turnover levels; and the growth in ‘benchmark’ turnovers based on applying year-on-year ‘productivity’ (‘efficiency’) growth rates to all existing and new retail floorspace”.
Problems with this Approach
6. The problem of adopting this approach is that any existing overtrading in existing retail stock is simply accommodated into the benchmark figures and it is then assumed that this will continue (and in fact will worsen due to increases in expenditure availability) over the Plan period.
7. The importance of this deficiency of the BCCS is that the approach to the formulation of retail policy in the BCP is heavily influenced by the outputs of the Study and particularly the findings that there is only a very small requirement for new retail floorspace (for both convenience and comparison goods) over the Plan period. This has led to the formulation of policy which sets unduly high hurdles for new edge or out of centre development to achieve, coupled with no policy incentive for LPAs to review and expand their designated centre boundaries to accommodate no new retail development in the second tier development plans. The outcome from such a strategy will be to deter investment from the few retailers still seeking to deliver new retail facilities existing residents, in particular the discount retail sector, which, as acknowledged at paras 2.23 and 2.41 of the Main Report (Vol 1) of the BCCS, are still actively expanding their portfolio of stores.
Resultant Retail Policy Issues
8. Of particular concern regarding the formulation of retail policy in the draft BCP, which we consider is directly influenced by the outputs of the BCCS, is the setting of a local threshold of 280 sq m gfa for the submission of retail impact assessments for all edge or out of centre retail proposals (ref Policy CEN6). We make separate representations on that matter. However, it is pertinent to state here that this very low (and in our view unjustified) threshold is a direct consequence of the view that as there is very little qualitative need for new convenience retail floorspace. Accordingly, virtually any scale of new proposal will necessarily have to draw its trade exclusively from existing retail outlets (rather than from growth in available expenditure) and this could give rise to harmful impacts (see para 8.59 of the BCP). We consider that such a perspective is based on speculation rather than evidence and does not form a sound basis to construct policy.

Comment

Representation ID: 45893

Received: 11/10/2021

Respondent: Transport for West Midlands

When looking at trips at peak times, only 15% of all travel is to or from the key strategic centres of the Black Country, with 85% of people travelling elsewhere across the region. So while we want to maintain the role of such centres, especially for shopping and leisure trips we also see the relevance of smaller, neighbourhood centres and how improvements to these, and the development of ‘15 minute neighbourhoods,’ may help encourage more active travel and more localised access to key services. Tier 2 and 3 centres especially may lend themselves well to being ‘15 minute neighbourhoods’, especially where new development is taking place and this should be explored as a potential policy in the Black Country Plan.

Around 80% of travel to key centres is also for retail and leisure purposes, and we feel the economic benefits of footfall generated by public transport and active travel modes is often underestimated in such centres and needs to be more strongly emphasised in the policies.

Comment

Representation ID: 45935

Received: 28/09/2021

Respondent: Mr & Mrs Allan & Rosalind Male

Number of people: 2

Surplus retail capacity in town centres should be converted or redeveloped to provide residential accomodation or other business use [maybe small to medium workshops].