Policy CEN1 - The Black Country Centres

Comment

Representation ID: 10796

Received: 10/09/2021

Respondent: NXD Consulting Ltd

The Black Country is blighted by empty and non-commercial high streets which, with more creative thinking, could be adapted to bring in smart residential units linking in with such things as the new metro extensions. Not only would town centres benefit from increased footfall but there would be a massive community benefit in having more affordable housing based within walking distance of public transport facilities for commuting to larger commercial centres such as Birmingham. The major focus must be on these types of integrated schemes to reduce carbon emissions and increase a sense of well being rather than taking the easy way out through increased greenbelt destruction

Comment

Representation ID: 11329

Received: 30/09/2021

Respondent: Miss Holly Harrison

BRIERLEY HILL STRATEGIC CENTRE - YES TO DIVERSIFYING USES, ALSO BRING BACK MONORAIL

2-BRIERLEY HILL STRATEGIC CENTRE
The retail scene is changing and let’s face it – more and more stores are moving to an online presence only. What can fix this? One might suggest bringing back the ever-loved monorail... sustainable transport anyone? But as this is probably a distant dream, I support the diversification of uses to generate a more stable daytime and evening economy.

Comment

Representation ID: 11339

Received: 30/09/2021

Respondent: Mr Paul Jackson

Following the pandemic should the plan be reviewed anyway as we are seeing many offices closed that could be converted to apartments/flats.We would still have an infrastructure problem but easier to fix than concreting over green belt that would be gone forever

Comment

Representation ID: 11365

Received: 30/09/2021

Respondent: Mrs Christine Hedges

Brownfield and town regeneration should aim to retain important historical landmarks, features and buildings to reflect our proud heritage.

Object

Representation ID: 12224

Received: 11/10/2021

Respondent: Firstplan

Hobart Partners own Oldbury Green Retail Park. The retail park provides the principal retail offer of Oldbury Town Centre given its proximity and good pedestrian connections to the adjacent Sainsbury's store and historic retail core. The site should therefore be included within the defined town centre boundary of Oldbury Town Centre.
Further supplementary information setting out our reasoned justification will be submitted shortly.

Comment

Representation ID: 13200

Received: 08/10/2021

Respondent: Mrs Jean George

With the town centre no longer being viable or fit for purpose, more consideration should be given to converting shops/ offices into affordable housing.

Comment

Representation ID: 13945

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy CEN1 - The Black Country Centres

London & Cambridge Properties Limited (LCP) is one of the UK’s largest property owners of retail and industrial, managing a portfolio in excess of 16 million sq ft which is held predominantly for long term investment purposes.
LCP own a number of retail centres in the Black Country Local Plan Area and are keen to play an active part in the emerging Development Plan process in order to inform the requisite planning authorities of their property holdings in their receptive areas.
They own the following retail centres: -
Churchill Shopping Centre Dudley
Aldridge Shopping Centre Aldridge
Astle Retail Park West Bromwich
Wulfrun Shopping Centre Wolverhampton
Park Place Shopping Centre Walsall
Quinton Court Shopping Centre Walsall
Rayner Parade Wolverhampton
35-47 High Street Brierley Hill
Centre House Aldridge
Scott Arms Sandwell
The Moors Shopping Centre Walsall
Dudley Street Sedgley

LCP want to ensure that all of these retail holdings are identified within either Town Centre, Tier One or Tier Two or Three centres. LCP will be ontinuing to invest in these centres and require policies to be flexible to allow a range of uses including retail, leisure and residential.
Emerging policies must be flexible given the ongoing difficult conditions with the retail sector at the moment.

Support

Representation ID: 17547

Received: 11/10/2021

Respondent: Sport England

Further to Sport England's comments on policies CSP2 and CSP3, Sport England recommends reference being added to part 1) of the policy to include sport and recreation uses within the list of appropriate uses, since this is consistent with NPPF Glossary definition of Main town centre uses, and links well the the later part of this paragraph which refers to fostering healthy communities and increasing social interaction and cohesion. An associated amendment to para 8.15 of the justification to add in reference to sports uses in part a) would also be recommended.

Comment

Representation ID: 17971

Received: 07/10/2021

Respondent: Mr and Mrs Philip and Valerie Rhead

Number of people: 2

I am nearly [age redacted] years of age and when I was younger Walsall was a fantastic town with fantastic shops. My family and myself were regular visitors to the town and we always enjoyed our visits. Now the town is a disgrace with many empty shop units and we only go there if we have to, which is very rare.
I have walked along Brownhills High Street and counted an empty garage workshop, a closed public house and 52 empty retail units. These empty units will not be used as shops again. Many have been empty for years. Even I have relented and purchased some goods online, this week, from Amazon, so the future of retail is now very much reduced from what it was.

Comment

Representation ID: 21974

Received: 06/10/2021

Respondent: Pat Barden

In town centres, we must use the areas above retail units for residential accommodation, thus regenerating the areas by providing homes for young singles and even older people who could benefit from being close to amenities.

There are now empty units on every high street which could be converted by either the councils (giving them the opportunity to regenerate council housing stock or profit by selling on, not to mention employment in the regeneration).

Comment

Representation ID: 23150

Received: 11/10/2021

Respondent: Black Country UNESCO Global Geopark Partnership

Agent: Black Country UNESCO Global Geopark Partnership

As stated in paragraph 8.2 ‘ The purpose of the centres policies is to help secure the investment, jobs and regeneration needed to create a mature, balanced, and well-functioning network of centres where residents shop, work, live and spend their leisure time’

We feel that under point c) of policy CEN 1 that reference should also be made to natural and cultural heritage links within the strategic centres and the important role that these centres will play in the visitor economy.Similarly, in Policy CEN 2 point 4) the natural and cultural assets of the strategic centres are missed and should be mentions. This comment also particularly applies to the edge of centre and out of centre sections as many links to cultural and natural features of the Black country will be found in these surrounding zones and add value to the strategic centres.

Object

Representation ID: 23365

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

We also note as a general point that much of the evidence used by ABCA pre-dates the COVID Pandemic and, as is acknowledged in several of the reports, the impact of this, as well as the longer-term impact of other upheavals, particularly BREXIT, remains uncertain. Most immediately the Pandemic has hastened the move towards on-line shopping and more extensive home working practices. These changes will directly affect the need for land and premises and free up opportunities for new housing, particularly in town and city centres, something acknowledged in the Centres Study (Para 3.36) and, even more importantly, an underlining factor in the decision of the Government in December 2020 to direct its housing uplift to the twenty largest cities (one of which is Wolverhampton).
As the attached report explains, there is considerable scope for new land to come forwards for housing from redundant retail and employment land and there are a number of ways this could be accounted for in the Plan, by ringfencing the Wolverhampton uplift (if it continues) for new urban regeneration sites, by identifying additional land in urban centres, by reviewing the criteria on redundant employment land, or by including a significant allowance for larger windfalls, perhaps in line with historic delivery.

Support

Representation ID: 23378

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CEN1
CPRE supports the emphasis on Centres and welcomes the inclusion of residential within the CEN1 (7). As well as meeting housing need and protecting the countryside such an approach will help to ensure the vibrancy of those centres. Particular consideration should be given to widening the socio-economic base of the Black Country, and designing schemes which capitalize on the transport links to the centres, such as access to the Chase Line at Walsall and the West Coast Main Line at Wolverhampton.

Object

Representation ID: 23379

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

However, we believe the policy needs to be more dynamic. In some cases, the best option for centres may be to contract in terms of retail to provide a more balanced and sustainable centre. While the impact of the increased contraction of retail and offices post-COVID remains uncertain, work towards the Regulation 19 consultations should directly address this.
Such an assessment may also specifically lead to a review of Policies CEN2-4 in terms of the balance of development and where any retail contraction is most likely to need to be managed and how. We are not commenting at this stage on that balance.

Support

Representation ID: 44944

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Lichfields

Policy CEN1 – The Black Country Centres

15.1 Taylor Wimpey supports the identification of Stourbridge as a Tier 2 Centre in Table 7 of the Draft BDP given the district centre function it plays in serving the needs of development in the area. We consider that the allocation of land at Clent View Road would support this role by helping to ensure its future vitality and viability, and to meet needs in the most accessible and sustainable way by providing new development with access to the centre via sustainable transport options.

15.2 We also note that Streetly is identified as a Local Centre in the emerging BCP. Therefore, the provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider Black Country is important. The development of the Chester Road site would support Streetly as a Local Centre by contributing to local convenience and comparison retail, services,
community facilities and other amenities.

Comment

Representation ID: 44975

Received: 09/03/2022

Respondent: Taylor Wimpey

Agent: Lichfields

CEN1 - The Black Country Centres
Taylor Wimpey supports the identification Of Stourbridge as a Tier 2 Centre in Table 7 Of the
Draft BDP given the district centre function it plays in sewing the needs of development in the
area. We consider that the allocation of land at Clent View Road would support this role by
helping to ensure its future vitality and viability, and to meet needs in the most accessible and
sustainable way by providing new development with access to the centre via sustainable
transport options.
We also note that Streetly is identified as a I,ocal Centre in the emerging BCP. Therefore, the
provision of housing to maintain its role in the settlement hierarchy of Walsall and the wider
Black Country is important. The development of the Chester Road site would support Streetly
as a Local Centre by contributing to local convenience and comparison retail, services,
community facilities and other amenities.

Comment

Representation ID: 45920

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

Policy CEN1 – The Black Country Centres



48. The large sale of population and housing growth proposed in the draft BCP will impact
on the use and operation of the centres. Policy CEN1 encourages the expansion of
the leisure evening economy.



49. The CCWMP objects to the lack of appropriate wording within Policy CN1 policy to
address the expansion of the leisure evening economy which will impact Policing. It
would be unsound for the impact of this significant area of growth and development to
be ignored as it could potentially undermine the Plan’s vision and objectives and the
sustainable development objectives of the NPPF.



50. The CCWMP considers that the general objectives of evening specific issues for any
decision-maker include: ensuring a thriving, vibrant economy where people can feel
safe, with reduced crime and a reduction in the fear of crime.



51. The problems of the evening economy can include: if crime or the fear of crime
increases, people will not feel safe, are unlikely to use the entertainment/night-time
facilities, with the potential of an economic spiral of decline. This can result in the
closure of bars, restaurants and shops, less people being attracted to the area, leading
to the closure of more premises and companies going out of business.

52. Safety issues of particular relevance to the evening economy include for example:



• Access to and from the facilities (e.g., nearby public transport network,
access to taxis and private-hire vehicles);
• Safe and reasonably-priced parking facilities (well-lit, accessible car
parks where people feel safe, with CCTV and good access control)
meeting the standards set in the NPCC Park Mark accreditation scheme;
• Well-run premises, with qualified/licenced door staff, who are able to deal
with the conflict and problems associated with such premises, as well as
presenting a welcoming ‘customer-service’ approach to people visiting
the City and the premises concerned;
• CCTV facilities within bars, clubs and restaurants;
• Licensed premises and ‘change of use’ planning applications;
• Hot food takeaways/late-night refreshment houses can be the flashpoint
for violence after the pubs and clubs close;
• Late opening off-licences and small retail stores (that sell alcohol) tend
to be ‘honey pots’, i.e. areas where people tend to linger for longer than
they would normally do so and attract increased levels of anti-social
behaviour;
• Position of Automated Teller Machines (ATM) both ‘hole in the wall’ and ‘stand-alone’. These are often situated in night-time economy areas and
can become ‘crime-generators’;
• ATMs and ATM replenishments. Across the UK there have been an
increased number of physical attacks on ATMs, including the use of gas
and ‘cash in transit’ robberies from cash vans, of particular concern
where an apartment or dwelling is above the premises.



53. The CCWMP requests that the policy be modified by the introduction of the following
text shown in bold:



‘In order to have a successful evening economy it is important
that a variety of facilities, appealing to a wide range of age and
social groups, are offered and that these are provided in such a
way to ensure a safe, accessible and inclusive environment and
any anti-social behaviour is discouraged, for example through
management, improved lighting and CCTV coverage where
appropriate.’



54. In addition, just as has been highlighted in response to Policy CSP5 ‘Cultural Facilities
and the Visitor Economy’ the CCWMP highlights the need to consider the threat of
terrorism and measures to minimise crime and anti-social behaviours which can be
associated with large gatherings, such as in town centres.



55. All locations which will generate crowds in public places should consider the need for
appropriate security measures in the design of buildings and spaces. Good counter-
terrorism protective security can also support wider prevention. PPG identifies a
number of sources of guidance in this respect including ‘Protecting Crowded Places:
Design and Technical Issues’, which refers to ‘Secured by Design and ‘Safer Parking’
standards.



56. The NPPF is clear in its requirement that local planning authorities should anticipate
and address possible malicious threats, especially in locations where large numbers of
people are expected to congregate. It states that, ‘Policies for the relevant areas (such
as town centre and regeneration frameworks) and the layout and design of
developments, should be informed by the most up-to-date information available from
the police and other agencies about the nature of potential threats and their
implications. This includes appropriate and proportionate steps that can be taken to
reduce vulnerability, increase resilience and ensure public safety and security.’



57. The CCWMP therefore requests that the following wording be added to Policy CEN1
as follows:



‘An assessment will be required to be undertaken as part of the
design of new developments where large numbers of people are
expected to congregate to demonstrate, through a fully
documented process, that potential security and crime related
vulnerabilities have been identified, assessed and where
necessary, addressed in a manner that is appropriate and
proportionate.’