Part Two: Centres and Site Allocations (Regulation 18)

Comment

Representation ID: 485

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

VISION AND OBJECTIVES

Page 9 point B -Vision and Objectives
Night time economy is all very well, but the Plan needs to recognise the negative impact this can have on people who live adjacent to such uses given the growth of people living in flats above shops in our towns.
We do not feel that there is a need for more pubs in Brierley Hill, and some of the extended licencing hours for the existing pubs already cause issues for people who live in the High Street town centre.

Page 11 paragraph 1.9. Good to see the aspiration to link the Merry Hill centre in to the rest of the urban fabric.

Comment

Representation ID: 486

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

There is little in the plan about achieving connectivity across the strategic centre of Brierley Hill. In fact this is only referred to once. “Delivering an integrated and accessible town centre” was a key objective of the Council’s 2011 Brierley Hill Area Action Plan – why is this not a key objective of the current draft Plan?

See pages 8-11 of the AAP which set out this as the first challenge for the AAP.

AAP 2011 page 9 - “New connections need to be made between the High Street, Waterfront and Merry Hill, and their surrounding areas, and sustainable transport options need to be enhanced to improve access to everyone”.
Given that Brierley Hill is now the strategic centre of the borough, we would expect a lot more emphasis to be placed on the need to join up its separate elements. This should once again be a core objective of the new Local Plan.

At the moment Brierley Hill High Street, Merry Hill and the Waterfront all have very different identities and are effectively separated from one another by topography and physical barriers.

If one of the intentions of the plan is to promote Brierley Hill as a strategic centre, a key objective of the plan should be to propose ways in which these three distinct areas can be more effectively integrated. This could include physical connections such as bridges across the canal, better connectivity between the Waterfront and Merry Hill across Level St.

The potential residential development of sites between Merry Hill and Brierley Hill clearly offers the opportunity to create linkages and join up these areas. It is really important that when these sites are developed the opportunity is taken in their design to achieve a relationship with both Brierley Hill and Merry Hill.

Object

Representation ID: 487

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

See full response in attachments.

We are pleased to see that the Council has revised downwards its housing target for Brierley Hill to a more realistic level. However we do not consider that the high density of development proposed for most of these sites meet the housing need in the area nor is it deliverable in terms of market demand.

Figures calculated using data from Housing Strategy show there is as much as a need for family housing as there is one bedroom flats in Brierley Hill. Data analysis shows that there is already a disproportionate amount of one bedroom flats in Brierley Hill compared to the wider Borough.

Analysed data which showed the draft Local Plan proposes that a minimum of 71% of new homes in the Strategic Centre will be high density, ie, flats.

It is very clear therefore that this part of the Plan is unsound as it proposes a mix of housing for Brierley Hill which will not meet the local housing need. The Plan should be revised to emphasise the need for more family housing and less flats.

Market demand for flats is not there. Flats more challenging for cash flow for developers also.

Comment

Representation ID: 488

Received: 19/12/2023

Respondent: Brierley Hill Community Forum

Housing at the Merry Hill Centre

We would like to see included as an aim in the plan the development of high quality housing within the Merry Hill shopping centre or car parks.
We believe that the centre will never achieve full occupancy again as a result of the changes to retail patterns and both part of the centre and the extensive car parks could be repurposed with a high quality residential offer.
We recognise that the current owners of the site are not considering this option, but longer term we think it is an appropriate aspiration.