Comment

Representation ID: 438

Received: 19/01/2024

Respondent: Dudley Labour Group

Dudley has an abundance of heritage and culture to offer as a visitor attraction.
However, we are not assured that this offer is being exploited to it’s full potential.
There is a need to create the right environment and to ensure there is a joined up
approach by DMBC, its key attractions and the hospitality sector, each working closely
with public agencies like WMCA and the Heart of England Tourist Board to better
coordinate a marketing campaign to attract further visitors to help deliver economic
benefits for Dudley .
It is essential the key findings of the recent LGA Peer Review as outlined on page 13 ,
third paragraph ‘ the tourism and visitor offer are important, and the Council could be clearer on how this could fit with the regeneration proposals . The development of a strategic marketing approach for the visitor economy would be useful ‘. This theme is captured as one of the key recommendations from the Peer Review , Recommendation 19 : Develop a place marketing approach for the visitor and tourism economy .

Support

Representation ID: 507

Received: 22/12/2023

Respondent: Sovereign Centros

Agent: Williams Gallagher

Support in principle for Draft Policy DLP5 which, inter alia, supports proposals for new developments or uses that contribute to the attractiveness of Dudley as a visitor destination subject to national guidance and policy requirements elsewhere in the Plan

Support

Representation ID: 697

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust welcomes mention of the canal network within para 5.33 of the justification text.

Object

Representation ID: 728

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP5 Cultural Facilities, Tourism, Heritage, and the Visitor Economy, P75. This policy
should include the following as a new sub-heading and paragraph, ‘Safety and Security 11. An
assessment should be undertaken (as part of the design of new developments likely to attract
large numbers of people) to demonstrate and document how potential security and crimerelated
vulnerabilities have been identified, assessed and where necessary, addressed in a
manner that is appropriate and proportionate.’
The reasoned justification could then refer to the following references, the following policy
background. Planning Practice Guidance (Paragraph: 011 Reference ID: 53-011-20190722)
recognises that for all locations which will generate crowds in public places, consideration should
be given to appropriate security measures in the design of buildings and spaces. Good counterterrorism
protective security can also support wider prevention. The 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.
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 at paragraph 97 that, “Planning policies and decisions should promote public
safety and take into account wider security and defence requirements by: a) anticipating and
addressing possible malicious threats and natural hazards, especially in locations where large
numbers of people are expected to congregate.
Policies for 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”.
The footnote to the above paragraph confirms this includes transport hubs, night-time economy
venues, cinemas and theatres, sports stadia and arenas, shopping centres, health and education
establishments, places of worship, hotels and restaurants, visitor attractions and commercial
centres.
The Delivery section to this policy could also refer to ‘Liaison with West Midlands Police’.
[Suggested changes in bold and underlined). [Objection]

Comment

Representation ID: 794

Received: 30/01/2024

Respondent: Historic England

DLP5. We welcome the inclusion of heritage as a feature within this policy.

Para 5.33. We welcome the inclusion of this paragraph.