Support

Representation ID: 948

Received: 21/11/2024

Respondent: Dennis R Whittaker

General support - but actual support or opposition would be on a site by site basis.

Comment

Representation ID: 1364

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

There is something of a mismatch between treating the whole of Brierley Hill as a tier one centre and three towns as tier two. Brierley Hill actually consists to two separate town centres – the Strategic centre of Merry Hill and the town centre of Brierley Hill proper (the High Street, etc). There is a spatial separation between the two, including in elevation. Development between them is unlikely to change that. Merry Hill Centre should be specified as tier-1, with Brierley Hill High Street, etc as at most tier-2. This will simplify the drafting of DLP24.5, enabling protection for floors 1 and 2 at Merry Hill Centre, but only ground floor in four more traditional town centres.
The Brierley Hill Town Centre boundary includes an area west of Pedmore Road, which is wholly or mainly Saltwells Nature Reserve. This seems peculiar, even bizarre. It would be much better to use that road as the boundary. Including it in the Town Centre suggests some sinister (and unwelcome) motive for it to be developed. I

Object

Representation ID: 1461

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The PCCWM objects and requires the strengthening of point 6 as follows to read:
'6. Measures to enhance the vitality, accessibility, and sustainability of centres, including maximising the extent, safety and security of the public realm, open space, provision of green infrastructure and vehicle charging points, including integration of ‘Secured by Design’ and ‘Park Mark principles.’ will be supported.' In addition, the Delivery section should add, 'Liaison with West Midlands Police’s Design Out Crime Officers'. [Suggested changes in bold and underlined).

The Consultation Statement rejects the PCCWM’s suggestions by indicating these matters are covered by Policy DLP39 and that a cross reference to that policy in the reasoned justification covers the point. However, there is no cross reference to DLP39 but in any event the PCCWM wishes to maintain his objection.

One further omission from this policy is in relation to the specific consideration of proposals affecting Gambling and Alternative Financial Services. There is a case for a specific policy reference on the following lines, “proposals for all pay day loan shops, pawnbrokers, and gambling uses will take full account of any issues concerning community safety, crime, and disorder and will, where necessary, seek advice from the police and other safety organisations.” [Suggested changes in bold and underlined).

Comment

Representation ID: 1479

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterates previous Regulation 18 comments.

Content that canal-specific implications arising from the Council’s Centres and Town Centres policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy DLP36 Canals. The inclusion of the canal network within relevant allocation maps helpfully enables developers to identify canal related constraints at an early stage and engage with us accordingly. Requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice directly.

Support

Representation ID: 1484

Received: 11/12/2024

Respondent: Sovereign Centros

Agent: Williams Gallagher

We continue to support the overarching provisions of Draft Policy DLP24 which make clear that the priority for Dudley’s Centres
(including Brierley Hill Strategic Centre) is to ensure that they remain focused on serving the needs of their communities while enabling
centres to repurpose and diversify by providing a well-balanced mix of commercial, business and service functions. This includes both
retail provision and a mix of leisure, office, residential and other appropriate, complementary town centre uses that are accessible by a
variety of sustainable means of transport.
We also support the amendment to Policy DLP24 which responds to our comments on the Regulation 18 Consultation Version of the
Local Plan (wording changed at Point 5 to reflect that Merry Hill is a managed shopping centre with both the ground and upper floors
lending themselves well to the provision of a wider mix of uses (where such uses (including main town centre uses falling outside of Use
E)).
For context, and in respect of the Regulation 18 Consultation Version of the Local Plan, we had expressed concern that Point 5 of the
policy (which specifies the types of uses that can come forward at ground and upper floors in town centre locations) was somewhat
ambiguous and could lead to misinterpretation in respect of Merry Hill. Indeed, the ground and upper floors of this part of the Brierley Hill
Strategic Centre (a Tier 1 Centre) do not perform in the same way that a traditional town centre would. To control uses in this way at
Merry Hill (i,e. Use Class E at the lower level and wider uses on the upper floor) has the potential impact on the ability of the owners of
the Centre to adapt and respond to market demand in the interests of its valued customer base.
In reality, and whilst the primary focus of the Centre will be retail for many years to come, both the ground and upper floors lend
themselves well to the provision of a wider mix of uses (where such uses (including main town centre uses falling outside of Use E) which
enhance the viability of the wider Strategic Centre and Merry Hill complex. The fact that the Centre is in one single ownership also allows
the mix of uses to be managed in such a way that promotes and enhances its vitality without leading to the types of impacts usually
attributed to certain non-E Class town centre uses (e.g. anti-social behavior, littering, noise).
We therefore argued that the ground and upper floors of the Merry Hill Shopping Centre should both be allowed to diversify beyond that
of an E Class use where demand is identified, and that such uses are appropriate to its designated town / strategic centre status. Such an
approach would allow the Centre to adapt to the ever-evolving retail market as well as accommodate new and exciting town centre
appropriate uses, that are not necessarily covered by Use Class E, but which drive footfall and enhance the vitality of the Centre in the
same way that a traditional retail / Class E Use would.
It was also argued that the above approach would also align better with Bullet 3 of draft Policy DLPBH1 which noted that the
diversification and re-purposing of Brierley Hill Strategic Centre will be supported by approving development which enhances the viability
and vitality of the centre.