Sandwell Local Plan - Reg 19 Publication

One suggestion is to amend SEC4 by removing requirements 2a and 2b. The terms of leases or tenancies govern the interests of occupiers and occupiers make Investment decisions in the knowledge of how long they have secure tenure. The remaining clauses of SEC4, and other policies in the plan provide controls over any redevelopment.
An alternative would be to divide sites covered under SEC4 into those where continued industrial use is preferred and those which would benefit from comprehensive redevelopment for housing or other uses. The latter category would include sites, such as 2942, where the current “non-conforming employment uses” (see policy HO2, paragraph 7.13) reduce the amenity of adjacent residential areas or cause other problems. A new housing policy would cover these potential housing sites. As residential development is not guaranteed to happen, these sites would not count towards meeting the housing requirement until permission is granted.

Policy SEC4 is unsound because it will be ineffective in achieving its aims. The intention of the ‘flexible’ policy is welcome, but the stringent conditions controlling housing or other developments in Clause 1b will prevent desirable redevelopment in many cases. Consequently, the policy will not fulfil the intentions in paragraph 8.31:” Policy SEC4 provides a flexible policy framework to guide development proposals in these areas. This policy supports Strategic Objectives 2 and 8.”
Clause 2 sets out the requirements to be met before housing redevelopment can be permitted. The first two requirements will be very difficult to satisfy, particularly where an employment area is in multi-occupation or ownerships:
“2. Development or uses under part 1(b) will only be supported where there is robust evidence that:
a. if the site is vacant, that it has been marketed for employment use for a period of at least 12 months, including by site notice and through the internet or as may be agreed by the local planning authority;
b. if the site is occupied or part-occupied, that successful engagement has been undertaken with the occupiers to secure their relocation;”
Despite its intention, the policy will tend to perpetuate inefficient and unsatisfactory employment uses in residential areas, while preventing housing or other developments that may improve residential amenity, reduce traffic problems, reduce the carbon imprint etc.
An example is Castle Street/ High St Tipton (site 2942). Its designation as a SEC4 site is appropriate. It provides low-cost premises but in an unsightly, complex, mix of poor-quality units in different ownerships, some vacant. There is a changing array of occupiers including motor repairers, a gym, playcentre, a wholesaler, the occasional cannabis farm and other unnamed businesses. Long-standing users include a taxi firm and snooker club,
There is a need for low-cost employment premises like these, but they can be bad neighbours for nearby housing areas. This area faces recent housing developments to front and rear, including a converted listed building. It is highly visible, being on a busy through route. It causes pavement parking and vehicle movements and lies on proposed cycle routes on High Street and Castle Street. Comprehensive redevelopment for housing could improve the amenity of neighbouring housing, improve the setting of a listed building, and address parking problems. However, given the complexity of the site, it will be difficult to satisfy the requirements of SEC4.2a and 2b. It is unlikely that a private investor will risk the complex, costly and lengthy process of land assembly without a firmer policy support. In contrast, ad hoc industrial developments and changes of use will be allowed without restriction, save those imposed by other policies in the plan.
There also appears to be inconsistency between the enhanced protection of occupiers under SEC4 and a lack of protection offered to existing occupiers on brownfield sites allocated for housing under SHO1 or windfall sites(SHO2). There is a similar inconsistency regarding vacant industrial land allocated for housing.

The development of the cycle network is welcome, but.an alternative is proposed to Route 118 in Tipton Green. Figure 13, and the interactive map shows cycle route 118 in Tipton Green running from the A4123 along Dudley Road(A4037), turning right into High Street and on to Tipton Station. A branch diverges down Castle Street crossing Park Lane West to link to the path along the former communication canal to the New Main Line Canal (National Cycle route 81).

Both routes are very challenging in terms of road layout and traffic conditions. Dudley Road is on the Stourbridge to Wednesbury key route. This busy road is used by HGVs and traffic is frequently queuing between High Street and the A4123 Birmingham New Road; There is associated congestion beyond the lights north-bound and along High Street. The High Street/Dudley Road junction is often blocked where these streams of traffic converge.. One side of Dudley Road has terraced housing and on-road parking and access to a care home; on the other side there is access to the H&R oil depot, used by tankers from Europe. There is no space for a safe cycle lane and the Dudley Road/High Street crossroads has seen several collisions this year.

In addition, the commercial units on High Street and Castle cause on-street and pavement parking. Both cycle routes have to cross the A457 towards Tipton Centre. This busy key road will carry more traffic when the major housing site at Coseley Village is complete. My suggested alternative to the two routes would create a more attractive and safer canalside route from the A4123 to Owen Street centre and the railway station.. It would support the strategy for Dudley Port and Tipton in line with Paragraph 3.49." Further opportunities exist to build upon the existing infrastructure, making the canals and greenspace a destination, linking to wider attractions such as the Dudley Canal Trust, Black Country Museum and Dudley Zoo, and joining up with Tipton High Street"

The route would branch off the A4123 cycleway west of the junction with Dudley Road to join the Dudley Tunnel Canal towpath (there is half-completed spur already). It would follow the towpath (National Cycle Route 54) under A4037, Dudley Road, to a new bridge over the Birmingham Old Main Canal near the canal junction. It would continue along the Canal towpath towards Tipton, crossing under the A457. It would then follow Route 118 along the former Communication Canal to Union Street in the town centre and the New Mainline Canal (National Cycle route 81).A branch would link to Owen Street via Unity Walk.
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It would require investment in a new canal bridge, but bold investments can have dramatic effects. The investment is quite modest in comparison with the cost of the Owen Street road road tunnel which was supposed, but failed, to regenerate Owen Street.. It would create an attractive feature on the canal. Some years ago in Warwick, a new cycle bridge over the River Avon linked a park to a segregated cycleway along a busy road. It has become a safe and well-used route to school and created new walking and cycling opportunities. The proposed cycle route is safer and more attractive than those in the Plan. It would tie in with the Plan’s vision for Dudley Port and Tipton by creating an off-road route linking the canals, Tipton centre and railway station and Dudley Canal Trust, the BCLM and Zoo.

I support the intention of paragraph 3.49 to improve links between the canals and wider attractions such as the Dudley Canal Trust, Black Country Museum and Dudley Zoo, and Tipton Owen Street. Centre: see representation ID1422 for a suggested improvement to links.

Paragraph 3.45 describes the decline in retail provision in Tipton(Owen Street) centre and the Council's current regeneration efforts. These efforts amount to the demolition of shops with flats above and replacement with very high density social residential units Whilst this contributes to housing supply in a location close to the railway station, it is at the cost of displacing several businesses which have either ceased trading or relocated elsewhere; fortunately the Post Office has secured premises within the remaining shopping precinct. Furthermore the Council has moved the library away from Owen Street. These changes will have reduced the already modest footfall and the continued presence of the one major retailer, Poundland, must be in doubt. A masterplan is needed to exploit the advantages of the town's twin canal frontages, proximity to major attractions in Dudley and railway station.