Support

Representation ID: 38

Received: 04/12/2023

Respondent: Mr Ian Tompkins

The intention to bring more homes/use areas over shops in Town Centres is also to be applauded as this will definitely regenerate town centres which are fast declining.

Comment

Representation ID: 111

Received: 19/12/2023

Respondent: Mr John Davison

Support the principle of including residential within town centres as this will reduce the 'ghost town' after dark problem. However it should be noted that wildlife will improve the wellbeing of people in town centres. There should be a stated ambition to increase soft landscaping (ie not all areas hard paved). There can be integral provision through bat bricks and also (to support starlings, swifts etc) swift bricks.
Soft paved (ie grass) areas can be employed for temporary uses such as outdoor concerts, markets etc

Comment

Representation ID: 441

Received: 19/01/2024

Respondent: Dudley Labour Group

It is essential that DMBC continues to secure funding and investment in our centres in line with these policies so they can adapt, evolve, and continue to thrive. As well as
delivering economic benefits, the centres are importantly a focal destination for residents to visit for leisure and social interaction as community hearts of the surrounding towns and neighbourhoods.

There is concern that little is noted in the DLP of the ongoing need to ensure the 15 local centres that provide an economic and community role in our neighbourhoods are not overlooked. These centres warrant more
than the annual vitality health checks to assess their conditions. The local centres are very much the beating hearts of their wards and the council need to ensure they remain fit for purpose, providing a valuable role as places for local shopping and meeting up.

Action plans and health checks should be carried out on these.

Support

Representation ID: 466

Received: 19/01/2024

Respondent: CPRE Worcestershire

WM CPRE supports the general approach to centres including the potential for some repurposing including residential development (Part 1) and upper storey residential accommodation (Part 5 (VII))

Support

Representation ID: 501

Received: 22/12/2023

Respondent: Sovereign Centros

Agent: Williams Gallagher

Support in principle for the overarching provisions of Draft Policy DLP24 which note 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.
Notwithstanding the above, we note that the supporting plan to this policy (i.e. the plan shown within the
consultation document at Page 164) is not the correct plan. We assume it is intended to be Figure 10.1 to
which Draft Policy DLP24 refers. The plan provided under the heading ‘Spatial Strategy Plan: Dudley
Borough Centres’ instead appears to be a key diagram of existing transport and movement. We reserve
the right to comment on a revised plan (or the correct version of Figure 10.1) in due course.
Finally, we would query the wording of the fifth and sixth bullets of the draft policy which in the context of
the main part of the Merry Hill Shopping Centre complex, which comprises of two levels, is somewhat
ambiguous and could lead to mis-interpretation.
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 (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 enhacences its vitality without leading to the types of
impacts usually attribued to certain non-E Class town centre uses (e.g. anti-social behavior, littering,
noise).
Based on ths above, we would argue 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 such
uses are appropriate to its designated town / strategic centre staus. Such an approach would allow the
Centre to adapt to the ever eolviong retail market as well as accommodate new and excisting, town
centre appropriate uses, that are not necessarily covered by Use Class E but which drive footfall and
enhance the vitality ofthe Centre in the same way that a traditional retail / Class E Use would.
The above approach would also align betetr with Bullet 3 of draft Policy DLPBH1 which notes 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.
We would be happy to discuss the above with officers and define suitable wording in due course.

Object

Representation ID: 540

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

Responding effectively to the changing role of town centres and interventions needed to prevent further decline during a severe economic recession and cost-of-living-crisis is considered important.

Office floor space issues within town centres – changing working patterns driven by the COVID-19 pandemic, increased home working, etc. The emerging Local Plan Review needs to explore ways of encouraging more office workers to return back to the borough’s main town centre locations in order to help support the future vitality and viability of these town centres.

The importance of promoting mixed-use developments within town centres to help support their vitality and viability is considered important. Particularly schemes which focus retail uses on the ground floor with residential and office provision uses located on upper floors.

Supporting the future vitality and viability of Brierley Hill High Street is considered very important. Photographic evidence within this Local Plan Representation shows the extensive town centre decline of this once vibrant town centre location.

Consistent and repeated failures of centres and retail studies and employment land previous background technical evidence base studies used to support earlier Dudley Borough Local Plan Reviews, the adopted Black Country Core Strategy (2011), and the now collapsed Black Country Core Strategy (BCCS) Review (Autumn 2021). Failure to deliver meaningful changes on the ground and deliver fit-for-purpose and effective planning policy approaches for earlier Local Plan Reviews. Previous centres studies prepared by private sector planning consultants are clearly not fit-for-purpose and do now warrant the significant financial expense of commissioning these documents from so called retail and employment land specialist private sector planning consultancies.

The Council now needs to use in-house expertise to complete such studies to avoid previous retail study failings, which consistently fail to deliver any meaningful and effective on-the-ground improvements within the borough’s main town centre locations centres.

Comment

Representation ID: 645

Received: 22/12/2023

Respondent: TfWM and WMCA

Similar to our comments concerning residential developments, in the general policy for centres across Dudley, public transport accessibility to differing tiered centres could further be considered, with a criteria in place to ensure that they are well served, by the core bus network. Similar public transport accessibility criterias have been developed for other local plans – ensuring varying hierarchies of centres are served by appropriate public transport provision.This could be something Dudley Council may want to consider developing within its local plan.

Object

Representation ID: 734

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP24 Dudley Borough Centres, the PCCWM suggests strengthening point 6 as follows, '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).
[Objection]

Object

Representation ID: 735

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

One potential 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). [Objection]