Comment

Representation ID: 950

Received: 21/11/2024

Respondent: Dennis R Whittaker

General support but the Policy should also apply when Hot Food Takeaway is claimed to be a secondary use.
It's so easy to circumvent Policy DLP29 by putting a few tables and chairs in the Shop and pretending to be a Restaurant.

Comment

Representation ID: 1367

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

The prohibition is likely to cause difficulties where a secondary school is within or close to a town or local centre: King Edward VI College, Stourbridge is within Stourbridge Town Centre. Old Swinford Hospital is within 400m of Stourbridge and its latest building (formerly Stourbridge College) has its main entrance on the edge of Oldswinford Local Centre. The principle of not having hot food takeaways available for use by pupils is good, but their main trade is in evenings long after pupils have gone home. The objective of the policy can therefore be secured sufficiently by imposing limitations on opening hours, rather than by a complete ban.

Object

Representation ID: 1462

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 supports the amendments made to policy DLP29, and in particular point 3 of
the policy which has been amended in line with the PCCWM’s requests, as follows:

'In all locations, planning permission for Hot Food Takeaways will only be granted where there would not be an adverse impact on public or highways safety. Regard will be given to:
a. Existing traffic conditions, including availability of parking spaces.
b. Availability of safe legal loading areas
c. Proximity to junctions, pelican crossings, bus bays and bus stops
d. Accessibility of the site by public transport and cycling
e. Secured by Design, Park Mark principles, and the need for a maintenance plan to reduce crime, the fear of crime and anti-social behaviour.’

However, the PCCWM objects to the Delivery section and the previous Regulation 18 objection is maintained with the addition of the wording: 'Liaison with West Midlands Police Design Out Crime Officers' still considered necessary (Suggested changes in bold and underlined).

Figure 10.2 Hierarchal Approach Monitoring
The PCCWM welcomes and supports the inclusion of Secured by Design principles.

Comment

Representation ID: 1485

Received: 11/12/2024

Respondent: Sovereign Centros

Agent: Williams Gallagher

We do not consider that the Council’s response to our previous comments on this draft policy (made in connection with the Regulation 18
Consultation Version of the Local Plan) to be sufficiently robust to justify no amendments to its wording:
“Noted, however no change” (Page 97 of 231 of the Dudley Local Plan Consultation Statement dated October 2024).
Our previous comments in respect of Draft Policy DLP29 are set out below for ease of reference. Furthermore, we understand an
oversupply of takeaways in a town centre location can lead to a poor-quality retail environment, especially on a high street with broken
ownerships, where there may be multiple shops closed and shuttered during the daytime. A high-quality managed shopping centre
environment however, which is managed in one-ownership, does not carry this same risk. The owners of Merry Hill are incentivised to
maintain a vibrant location for all of its tenants. Hot food takeaways tend to be open all day to cater for shoppers and are generally of a high
quality, with a variety of offers and cuisines.
We would urge the Council to reconsider and provide a more detailed response. We would otherwise request that the Inspector presiding
over the local plan examination (as and when this takes place) review and come to their own conclusions as to the soundness of this policy.
Until such time, we can only conclude that this policy (in terms of its applicability to Merry Hill) is unjustified and thus unsound.
We also query the requirement for a Health Impact Assessment when the criteria relating to the acceptability of proposals for hot food
takeaways is already extensive. It is also unclear as to what such an assessment will need cover.

Reference to Reg 18 Rep - REP ID 501-509