Policy CSP2 – The Strategic Centres and Core Regeneration Areas

Comment

Representation ID: 11520

Received: 03/10/2021

Respondent: Richard Power

Pouk Hill public open space, Bentley Lane, Reedswood, Walsall.
• Given its natural green space sensitivity, critical public open space importance for local residents, and urban green lung sensitivity helping to significantly reduce harmful levels of air pollution from the M6 motorway network, the entire Pouk Hill green space site should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging Black Country Plan (BCP) (Review) (2021).


Public open space located North of Churchill Road and the Jane Lane School, Reedswood, Walsall.
• The entire green space site should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).

Reedswood Town Park public open space
• The entire Reedswood Town Park public open space should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).

Former Reedswood Golf Course
• Given its natural green space and public open space sensitivity, the entire Former Reedswood Golf Course public open space should be removed from the 'Core Regeneration Area' designation as shown on page 499 (within Figure 19: Walsall Spatial Strategy Plan) of the emerging BCP (Review) (2021).

Comment

Representation ID: 11608

Received: 26/09/2021

Respondent: Ursula Walker

It is inappropriate to include Reedswood Town Park in the proposed Core Regeneration Area.

Support

Representation ID: 12012

Received: 10/10/2021

Respondent: Miss Emma Thompson

no comment

Comment

Representation ID: 12294

Received: 30/09/2021

Respondent: Mr Martin Lynch

I'd ask what the implications of the original central area of Reedswood Park being apparently currently designated within 'Core Regeneration Area' of the Black Country Plan?

Comment

Representation ID: 12295

Received: 30/09/2021

Respondent: Mr Martin Lynch

I'd ask what the implications of the original central area of Reedswood Park being apparently currently designated within 'Core Regeneration Area' of the Black Country Plan?

Comment

Representation ID: 12929

Received: 20/10/2021

Respondent: Mrs Elizabeth Lloyd

Suggests the town is redeveloped for housing instead.

Comment

Representation ID: 13544

Received: 20/08/2021

Respondent: David Archer

Sirs,

I see with great sadness that we are being ' forced' by HMG to forsake
some of our precious green belt and wild places (Like Pelsall North
Common and the old Pelsall Steel works site)

My view is that we should use vacant properties not in use for housing -
West Midlands Combined Authority's insistence on using brownfield sites
as a priority is, in my view, the correct and proper way to gain more
space for houses. Unfortunately insufficient opportunities of this type
have been identified to comply with HMG's requirements of increasing the
housing stock to their desired level.

However, it is evident to all that our town centres are dying and
becoming deserts - few people visiting and even fewer shops surviving.
Surely it makes sense to redevelop vacant shopping areas and properties
for housing rather than using green belt and wild places.

I bring to mind 2 huge areas in Walsall - the Old Square and Saddlers
centre. In historical terms these areas were housing and small family
owned 'upstairs' manufacturing areas during and after the industrial
revolution. Retail occupation has got to be below 20% at the moment with
little liklihood of that improving in the medium to long term.

Why not return them to housing areas?

Walsall council owns the Saddlers Centre - so in theory, they can do as
they please with this site.

Initial thoughts would be to develop that into a complete, cohesive and
integrated transport interchange hub freeing the areas of Bradford
Street and St Paul's for town centre type housing.

Similar sites exist throughout the whole of the Black Country -
Wolverhampton in particular comes to mind although it is now well served
for transport interchanges..

Using these sites would thus bring life back into the town centres,
restrict the demolition of Green Belt, and enable the existing transport
infrastructure to be better used without expensive extension to road and
rail provision.

In short - use what we have in a smarter way.

Best regards

David Arche

Comment

Representation ID: 13836

Received: 11/10/2021

Respondent: Living Space Housing Ltd

Living Space understand why the Councils have taken the approach of focusing new development around the Strategic Centres and Core Regeneration Areas. The existing centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton are the most sustainable locations within the Black Country and new development can help these communities to continue to grow in a sustainable way. However, it is important to recognise the benefits that new development can bring and the Councils should ensure that there is a good distribution of growth throughout the districts. This will help ensure that all communities have the opportunity to grow and develop in a sustainable way. The Councils should also be cautious with their proposal to locate the majority of new development within the existing built-up area. The majority of this will be required on brownfield sites and will be dependent on the viability of said site. The development of brownfield sites is often as the expense of providing any on-site affordable dwellings.
1 Paragraph 66 of the National Planning Policy Framework (NPPF) (2021)

Object

Representation ID: 14482

Received: 11/10/2021

Respondent: John Rowley

The draft BCP is not robust enough to protect the city’s natural environment from development.

CSP 2, on page 26, seeks to deliver growth and development by …..e) ‘Protecting the openness, integrity and function of the Black Country’s designated and retained Green Belt by resisting inappropriate development;’
This aim has been lifted word for word from the BCCS. It appears in similar form in Wolverhampton’s UDP, yet outline planning permission for an inappropriate development of 14 houses was nevertheless allowed on the former Wolverhampton Environment Centre (the WEC) in March 2018. [Table 43 ]
The definition of ‘exceptional circumstances’ in paragraph 3.14 of the Justification needs to be strengthened. It is difficult to see how building expensive houses on Green Belt land can be justified by the need to raise cash, as happened with the WEC, especially when there are brownfield sites and sites with previous planning permission waiting to be developed in Wolverhampton.
2. Paragraph 3.15 accepts that green spaces should be assessed…with regard to the wider area but I could find no consideration in the BCP of the impact South Staffs Spatial Housing Strategy will have on Wolverhampton’s Green Belt - context CSP , paragraph 3.49. We may be ‘surrounded’ by open countryside on north, west and south at the moment but not for ever.

Support

Representation ID: 17523

Received: 11/10/2021

Respondent: Sport England

Sport England would encourage the Authorities to add a reference to uses for sport and recreation within part 3b) of the policy. Whilst leisure is already included in the policy, this is taken to mean commercial leisure uses rather than sports uses. Sports uses are referenced separately from leisure uses within the NPPF Glossary for the definition of Main town centre uses, and so it would be entirely appropriate to reference sports and recreation uses within this policy.

Comment

Representation ID: 18069

Received: 11/10/2021

Respondent: Brierley Hill Community Forum

Large scale regeneration projects can have a huge impact on local community organisations. Post war regeneration in the Brierley Hill area entailed many people moving away from their local communities. This has had an impact on the long term viability of community and faith provision.

The rate of turn-over amongst younger residents in high density accommodation (for example Brierley Hill flats) makes it increasingly difficult to build strong community organisations due the constantly changing population.

Comment

Representation ID: 18125

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraphs 3.11 to 3.13 - This policy should mention Neighbourhood Growth Areas and have equal importance with Strategic Centres and Core Regeneration Areas. A more balanced approach is needed in accordance with the vision and CSP1.
"the justification for the approach set out in CSP2, focusing growth solely in the Strategic Centres and Core Regeneration Areas" "The narrow focus set out in CSP2 also conflicts to an extent with paragraph 3.15 which acknowledges that Green Belt status should not be the sole criteria in assessing the suitability of a site’s ability to deliver sustainable development." "The justification to CSP2 actually highlights the failings of such a narrow
approach, in that it would only deliver housing on 'poor quality and underused land' which will not deliver a range of housing opportunity sites nor reflect the need to provide choice in both types of accommodation but also location."

Object

Representation ID: 18377

Received: 11/10/2021

Respondent: Burrowes Street Tenant Management Organisation

Agent: Burrowes Street Tenant Management Organisation

I'm Secretary of Burrowes Street Tenant Management Organisation and my Co-Signatory, Madeline Moorcroft is Chair of the same. Our objections are as follows:
We and fellow tenants and residents live in a densely-populated, deprived, inner area just north of the town centre and immediately off the busy, congested, polluting ring road; our estate comprises nearly 300 high- and low-rise flats, and we are surrounded by likewise tightknit terraced nineteenth-century streets, and we are dismayed to learn that the green space we do enjoy and need could be under threat from housing development under the Black Country Plan proposals.
Of particular concern is the prospect of losing the Sydenham Playing fields immediately north of the estate (bounded by Birch Street, Green Lane and Old Birchills), and - extraordinarily we are advised that even Reedwood Park could be a target for housing development.
We already have plenty of new housing (eg. the Caparo site now well under way, and 130 flats to be crammed on the small Green Lane Police Station site), and we would find even more housing being built on our precious green space, including the green corridor which is the Walsall Canal, quite unacceptable,
And, when it comes to land near the M6 (which is pretty loud even from Reedswood Park), for example on the former tip at Pouk Hill, these green space have to stay as a 'green lung' to absorb noise and air pollution - not to mention the potential risk of landfill gas - and where there are proposals for redevelopment for housing so close to the motorway, these should be rejected out of hand.

Support

Representation ID: 18514

Received: 11/10/2021

Respondent: The Wildlife Trust for Birmingham and the Black Country

3b
Support: WTBBC support the recognition of the value of a high quality natural environment in Strategic Centres and the inclusion of this in Policy CSP2.
4d
Support: WTBBC support the recognition of the value of linked comprehensive networks of attractive green infrastructure in Core Regeneration Areas linking the Strategic Centres and the inclusion of this in Policy CSP2.

Support

Representation ID: 20976

Received: 11/10/2021

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas
We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas in the first instance and these being the focus for regeneration and investment. It is considered appropriate that new development should be directed to where it is most needed but also where it is best able to accommodate it in terms of accessibility and existence of facilities and services to serve new development. Locations such as these are considered suitable for higher density development, which will be biased toward a range of smaller units, where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.
Notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas we welcome the fact that the BCA acknowledge that most of its growth requirements cannot be met within these areas. That is not to undermine their role or the continued benefits that the regeneration of these areas will bring, but an acceptance that the development needs are now such that alternative sources of supply are needed if the development needs are going to be met.

Support

Representation ID: 21240

Received: 11/10/2021

Respondent: Newlands Developments

Core Regeneration Areas
The strategic approach for the growth network is set out within Draft Policy CSP2. We are supportive of this policy, in particular Part 4(a) which states that the Core Regeneration Areas linking the Strategic Centres will provide the principal concentrations of strategic employment areas. These are high quality employment areas that will be safeguarded and enhanced for manufacturing and logistics activity to support the long-term success of the Black Country’s economy. Furthermore, Part 4(c) advises that the Core Regeneration Areas will provide the principal locations for new industrial and logistics development: providing 192 hectares of developable employment land to meet growth needs. As noted above, the Site is located within the Walsall to Wolverhampton Core Regeneration Area and has a development capacity of 11.22 hectares.

Object

Representation ID: 21363

Received: 11/10/2021

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Policy CSP2 - The Strategic Centres and Core Regeneration
Areas


5.1 The core areas are proposed to provide a mix of housing and local employment land that are vital in providing for local jobs as well as strong links with the surroundings, knitting together old and new.

5.2 The BCP acknowledges the need for economic growth as one of the key issues for Core Regeneration Areas strategy and proposes the protection and enhancement of sustainable employment land. It also refers to the release of poor quality or underused land to support the regeneration.

The Core Regeneration Areas

5.3 Policy CSP2 refers to two key issues arising from the evidence base:


• Provide for economic growth through the protection and enhancement of sustainable employment land and premises.

• Delivering housing growth through the release of poor quality and underused land.

5.4 It is not considered that the Core Regeneration Areas are protecting and enhancing sustainable employment land. Sustainable employment sites are allocated for housing as part of the BCP despite being in sustainable locations and housing established businesses, despite the employment land shortfalls discussed in Section 3 of these representations.

5.5 We do not find these allocations to be effective considering the uncertainty surrounding the delivery and the sustainability benefits related to the continued use of occupied employment sites within The Black Country.

Comment

Representation ID: 21476

Received: 11/10/2021

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy CSP2 – The Strategic Centres and Core Regeneration Areas

2.6. This Policy identifies that the primary focus for regeneration and infrastructure will be the Growth network, which consists of the ‘Strategic Centres’ and the ‘Core Regeneration Areas’. The policy establishes that 11,208 new homes will be delivered within the Core Regeneration Areas, ‘in sustainable locations well-supported by community services and local shops, set within and linked by comprehensive networks of attractive green infrastructure with cycling and pedestrian routes’.

2.7. This policy is supported, however in light of the housing shortfall identified in respect of Policy CSP1, it is considered that the Council should be seeking to increase the amount of housing to be delivered in both the Strategic Centres and Core Regeneration Areas. This in particular should include identifying all opportunities for residential development within the urban area, recognising that such locations are typically the most sustainable.

2.8. It is considered that this should include identification of land at Corbett Hospital, as promoted by Charles Church Homes and The Dudley Group NHS Foundation Trust, as the site lies within one of the Core Regeneration Areas. It provides an opportunity to deliver high quality residential development within the urban area, in close proximity to existing services and facilities. By utilising sustainably located sites such as this, it would be possible for greater numbers of housing to be delivered within the Growth Network identified by the Plan, and for the Plan overall to be more able to meet its housing needs.

2.9. As such, it is considered that Policy CSP2 should be reviewed once the Council has fully taken into consideration all available sites, including land at Corbett Hospital, and propose that greater numbers of housing are delivered through these defined areas.

Comment

Representation ID: 21487

Received: 11/10/2021

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy CSP2 – The Strategic Centres and Core Regeneration Areas

2.6. This Policy identifies that the primary focus for regeneration and infrastructure will be the Growth network, which consists of the ‘Strategic Centres’ and the ‘Core Regeneration Areas’. The policy establishes that 11,208 new homes will be delivered within the Core Regeneration Areas, ‘in sustainable locations well-supported by community services and local shops, set within and linked by comprehensive networks of attractive green infrastructure with cycling and pedestrian routes’.

2.7. This policy is supported, however in light of the housing shortfall identified in respect of Policy CSP1, it is considered that the Council should be seeking to increase the amount of housing to be delivered in both the Strategic Centres and Core Regeneration Areas. This in particular should include identifying all opportunities for residential development within the urban area, recognising that such locations are typically the most sustainable.

2.8. It is considered that this should include identification of land at Corbett Hospital, as promoted by Charles Church Homes and The Dudley Group NHS Foundation Trust, as the site lies within one of the Core Regeneration Areas. It provides an opportunity to deliver high quality residential development within the urban area, in close proximity to existing services and facilities. By utilising sustainably located sites such as this, it would be possible for greater numbers of housing to be delivered within the Growth Network identified by the Plan, and for the Plan overall to be more able to meet its housing needs.

2.9. As such, it is considered that Policy CSP2 should be reviewed once the Council has fully taken into consideration all available sites, including land at Corbett Hospital, and propose that greater numbers of housing are delivered through these defined areas.

Support

Representation ID: 21628

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Land at Heath Street/Cranford Street, Smethwick,
Sandwell, B66 2QZ

Policy CSP2: The Strategic Centres and Core Regeneration Areas
Limb 2 of draft Policy CSP2 of the BCP states that the Strategic Centres and Core Regeneration Areas (CRAs) are the primary focus of new development, regeneration and infrastructure investment.
The CRAs, amongst other things, will be the location for approximately 11,208 new homes in sustainable locations throughout the Black Country. Our client welcomes the site’s inclusion within the CRA.

Comment

Representation ID: 22129

Received: 11/10/2021

Respondent: Brockmoor Properties Limited

Agent: CBRE

Policy CSP2 (The Strategic Centres and Core Regeneration Areas)
The Brockmoor Foundry sites are located within a Core Regeneration Area, identified as the primary focus for new development, regeneration and infrastructure investment. As set out in the response to policy CSP1, it is agreed that Core Regeneration Areas should be a focus for sustainable growth.

Part 4)d) should refer to 'at least' 11,208 homes to account for flexibility over the plan period and remain consistent with NPPF paragraph 61. These additional words should be added to the policy.

Part 4 should also recognise that within Core Regeneration Areas, housing development should come forward as a mix of sized sites to ensure consistent delivery over the plan period, which will come together to achieve the strategy, including allocated and windfall sites.

Comment

Representation ID: 22187

Received: 11/10/2021

Respondent: Druids Heath Golf Club

Agent: Harris Lamb

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities. The Strategic Centres and Core Growth Regeneration Areas are suitable for higher density development where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

As of yet the neighbouring authorities have not agreed an approach to the distribution of the housing shortfall or identified allocations in their emerging Plans that could meet this shortfall, in combination with the shortfall arising from Birmingham City. There is no certainty that the housing shortfall can be met on sustainable and deliverable sites. It is, therefore, essential that the emerging Black Country Plan allocates as many sustainable and sustainable sites for development to help ensure that the overall housing requirement is met. As detailed in these representations, the Club has surplus land in its control that should be allocated for development to meet the housing requirement.

Comment

Representation ID: 22234

Received: 11/10/2021

Respondent: Steve Crutchley

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to the locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities. The Strategic Centres and Core Growth Regeneration Areas are suitable for higher density development where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

As of yet the neighbouring authorities have not agreed an approach to the distribution of the housing shortfall or identified allocations in their emerging Plans that could meet this shortfall, in combination with the shortfall arising from Birmingham City. There is no certainty that the housing shortfall can be met on sustainable and deliverable sites. It is, therefore, essential that the emerging Black Country Plan allocates as many sustainable and sustainable sites for development to help ensure that the overall housing requirement is met. As detailed in these representations, our client owns land at Barr Beacon that should be allocated for development to meet the housing requirement.

Support

Representation ID: 22370

Received: 11/10/2021

Respondent: ROSCONN STRATEGIC LAND

In terms of Policies CSP2 and CSP3, RSL fully supports their approach to the distribution of strategic growth to the most sustainable locations which are accessible to jobs and a range of services and facilities, whilst providing housing choice, underpinning the areas’ economic competitiveness and supporting the working population.

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.

Comment

Representation ID: 23183

Received: 11/10/2021

Respondent: Historic England

Limited reference currently to the themes of the historic environment and the policy would benefit from a specific reference to heritage.

Support

Representation ID: 23219

Received: 11/10/2021

Respondent: Heyfield Development

Agent: Harris Lamb

Policy CSP2 – The Strategic Centres and Core Growth Regeneration Areas

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas in the first instance and these being the focus for regeneration and investment. It is considered appropriate that new development should be directed to where it is most needed but also where it is best able to accommodate it in terms of accessibility and existence of facilities and services to serve new development. Locations such as these are considered suitable for higher density development, which will be biased toward a range of smaller units, where new residents would have the greatest access to commercial, cultural, leisure, entertainment and community facilities, as well as employment opportunities.

Notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas we welcome the fact that the BCA acknowledge that most of its growth requirements cannot be met within these areas. That is not to undermine their role or the continued benefits that the regeneration of these areas will bring, but an acceptance that the development needs are now such that alternative sources of supply are needed if the development needs are going to be met.

Support

Representation ID: 23305

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Harris Lamb

We generally support the objective of directing development to the Strategic Centres and Core Growth Regeneration Areas. Development should be directed to locations where it is most needed and that are best able to accommodate it in terms of accessibility to services and facilities.

However, notwithstanding the focus on Strategic Centres and the Core Growth Regeneration Areas, it is clear that there is insufficient land available in these areas for the housing requirement to be met. Indeed, the emerging Plan acknowledges that Green Belt land release is required within the Black Country. Even with the Green Belt land release that is proposed Policy CSP1 advises that a housing shortfall of a minimum 28,239 dwellings exists (as detailed in our response to Policy CSP1 and HOU1 we believe this is an underestimated) that needs to be delivered in other Local Authority Areas within the HMA.

Object

Representation ID: 23368

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CSP2
In general terms CPRE supports the aspirations of Policy CSP2, and particularly the intention to deliver more homes in urban centres. However, the figures given in CSP2 for housing supply appear to us conservative. The Black Country Centres Study, which was based on evidence predating the pandemic, suggests a reduction in the requirement for Retail Space, both for Comparison and Convenience Shopping.
Para 3.36 identifies the need for a new mix of uses, underpinned by housing in centres. CPRE would urge ABCA to review its approach to centres, adopting realistic assumptions about retail need, and whether some managed contraction is required. If this is done in advance of the Regulation 19 Submission it would allow the soundness of the Plan to be tested and could yield additional much needed housing within urban centres as well as making them more viable in the long term.

Comment

Representation ID: 23465

Received: 11/10/2021

Respondent: Birchills Agenda 21 Group

Number of people: 339

Dear Sir/Madam

I am writing to you to raise my concerns in relation to the Black Country Plan (Review). In particular, I have concerns that Walsall Council is proposing to include
the Pouk Hill urban green space area within a proposed designated "Core Regeneration Area" within figure 19: Walsall Spatial Plan Map on page 499 of the Black Country Plan (BCP) Regulation 18 public consultation document.

The Pouk Hill open space area forms a very important green space resource which I have used for many years as a place to exercise my dog and as a natural environment urban green area in which to relax. The urban area has increasing shortage of these important open space sites. Walsall Council does not appear to
have any credible evidence to back up and support its planning policy approach for this site. For example, the Council does not have an up to date and robust Green
Infrastructure Study. The Council's position on this issue is not based on credible or accurate information or robust evidence. The lack of appropriate evidence base is
concerning, given that the Council is, and has included, large parts of the Reedswood area (which contains sensitive public open space areas, including Reedswood Town Park) within a so called 'Core Regeneration Area".
This will result in the loss of sensitive public open space areas from the Reedswood area. Walsall Council is encouraging damaging patterns of development within the local area, which will result in a shortage of public open space for local residents to enjoy, to help support more physically active healthy lifestyles.


On this basis, there is a compelling and robust case to designate the Pouk Hill green space as LGS on the main 'Policies Map' of the emerging Black Country Plan
(Review). This designation should be brought forward as a matter of urgency. I request the urgent removal of the Pouk Hill green space areas from the proposed
Core Regeneration Area'.

This is a signed residents petition by local residents who live on Pouk Hill Close, Reedswood, Walsall. As local residents living within Pouk Hill Close immediately
adjacent to the Pouk Hill natural green space area, we specifically request that:

1) Given its high level of green space sensitivity, the Pouk Hill Close green space site off Bentley Lane, Reedswood, Walsall should be fully removed from the 'Core Regeneration Area' designation as shown on page 499 of the emerging Black Country Plan (Review) (2021) Regulation 18 public consultation document - within the Figure 19: Walsall Spatial Strategy Plan (and other parts of the emerging Black Country Plan which identify this site as a Core Regeneration Area. Within the Figure 19 Plan (Walsall Spatial Strategy Plan) and on the main Policies Map of the emerging Black Country Plan
(BCP) (Review), the entire Pouk Hill green space area should be specifically designated as a 'Protected Public Open Space area' (see below).