Wolverhampton City Centre Area Action Plan (AAP) Draft ... · Strategy. The focus of office provision at the Interchange, together with the strategy to support mixed-use development

1

Wolverhampton City Centre Area Action Plan (AAP) Draft Plan: Summary of Consultation Responses,

Council Responses and Proposed Changes

Table 1: Stakeholder Meetings p. 1

Table 2: Formal Consultation Responses p. 27

Table 3: Proposed Changes to Draft Plan in response to up-to-date information, changing circumstances and to correct errors p. 116

Appendix: Proposed Changes to Policies CC1 and CA11 (see separate document)

Key: Underlined Text to be inserted Struck through Text to be deleted BCCS Black Country Core Strategy WCC Wolverhampton City Council NPPF National Planning Policy Framework UDP Wolverhampton Unitary Development Plan SPD Supplementary Planning Document

Table 1: Stakeholder Meetings

ID Name and Date of Meeting

Summary of Main Questions/ Comments Council Response Proposed Change to Draft Plan

A Blakenhall Local Neighbourhood Partnership & Blakenhall Action Community Forum Meeting Thursday 22nd January 2015

If representations are submitted will they all be considered? Will planning conditions attached to permissions be enforced? Importance of Dudley Road as a gateway frontage into the City Centre, but there are a number of issues,

Yes Effective planning conditions will be included in decision notices of planning permissions, consistent with NPPF paras 203 and 206, and appropriate measures will be taken to ensure compliance with conditions. See response to ID 25 under CA10 below

See response to ID 25 under CA10 below

2



such as the pavement A number of issues relating to Car Parking were raised Interchange 10 is a positive scheme being delivered in the city centre What is the future of site 11g (former Metal Castings Site on the Penn Road)? Will a new ‘free’ school be located within the City Centre AAP boundary? Blakenhall LNP will submit a formal response to the consultation

See response to ID 25 under CA10 below Agreed. The scheme at site 3b is providing over £10m investment and Grade A office provision at a gateway location in the city centre. Planning permission has recently been granted for a car showroom on this site No proposals to allocate a site for a free school within the AAP boundary have been submitted. Any future proposals would be considered on their own merits. See also response to ID 25 under CA10 below Welcomed [see ID 25 under CA10 below]

See response to ID 25 under CA10 below See changes in Table 3 See response to ID 25 under CA10 below

B West Midlands Canal Partnership Meeting Wednesday 28th January 2015

Welcome being kept informed of, and the proactive engagement with, the AAP process

Welcomed, particularly the response of the West Midlands Metropolitan Area Canals Partnership [see ID 35 under CA4]

C Bushbury, Oxley and Fordhouses

Where is the investment going to come from?

Investment will predominantly come from the private sector, and

3



Community Action Network (BOFCAN)/ Pendeford Agencies Link Scheme (PALS) Meeting Tuesday 3rd February 2015

Why have we not heard about this plan before? Nobody wants to go into the city centre, what are we going to do about it?

the Council will use what mechanisms it can to facilitate the maximum investment, jobs and regeneration in the city centre. The Publication Stage will include a Delivery Plan The AAP Issues & Options and Draft Plan consultations were extensively publicised, and the purpose of officers attending community meetings to discuss the AAP is to provide the opportunity to directly engage with residents of Wolverhampton - see Consultation Report It is a priority to regenerate the city centre through increasing attractiveness and footfall. The whole spatial strategy of the AAP is based on consolidating the retail core and supporting this in adjoining areas through promoting a range of complementary uses, including promoting the evening economy.

D Exhibition, Wulfrun Shopping Centre 6th and 7th February 2015

Issue of Car Parking charges

It is appreciated that car parking charges are an issue being raised by stakeholders. Para 1.5.11 recognises Car Parking as a key issue arising from evidence gathering work. It is not within the

4



Specific City Centre problems, such as Victoria Street being too narrow causing congestion when emergency vehicles park and issues with the fountain in Queen Square Where is the money coming from? Site-specific drainage issues can impose constraints to future development. Re-locate open-air market to more central location in the city centre and footfall and regeneration will increase

remit of the AAP to set parking charges. A Car Parking Strategy is being undertaken for the city centre which will cover a number of issues including pricing Victoria Street is identified as a part of the city centre transport and public realm improvements (Ref 11 Fig 5). Maintenance issues with infrastructure such as the fountain in Queen Square are not within the remit of the AAP. Investment will predominantly come from the private sector, and the Council will use what mechanisms it can to facilitate the maximum investment, jobs and regeneration in the city centre. The Publication Plan will be accompanied by a Delivery Plan. A Geo-environmental desktop study forms part of the evidence base. The future of the Outdoor/ Indoor Market, currently located in the Westside Character Area, is an important issue which will be addressed by the Council in collaboration with interested

5



Issue of pedestrianisation More speciality and high quality brand shops are needed Rents and rates for shop units are too expensive, leading to potential investment going elsewhere and vacancy rates in the city centre remaining high

parties. The Council is committed to the continuation of the market. Policy CA2 and para 4.3.6 emphasises that as part of any future development Westside is still the preferred location for the Markets. Works currently underway to enhance the pedestrian environment in Market and Princess Street are part of the Council’s Transport and Movement programme, which included extensive consultation with the public and stakeholders. Agreed. The AAP supports a variety of retail uses coming forward, which could include speciality and high quality brand shops. It is appreciated that business rates/rents are an issue being raised by the business community and other stakeholders. Business rates/rents is an issue recognised in para 3.5 of the AAP Issues & Options report. However, it is not within the remit of the AAP to set business rates. It is recognised

Policy CC1 para 3.1.3, second sentence after “independent” add “high quality brand and speciality shops…” Para 1.5.5 add new sentence to end “The AAP is part of a collaborative approach and a comprehensive package of measures to support the sustained regeneration of the city centre.”

6



Attended the consultation event the previous year – what has happened since then? Different views on whether a new cinema should be provided in the city centre Differing views on whether Wolverhampton should seek to compete with Birmingham

that the AAP needs to be deliverable as part of a joined-up, collaborative approach with stakeholders, alongside other delivery mechanisms. The AAP Publication Stage consultation will be supported by a Delivery Plan. In terms of the preparation of the AAP, following the Issues & Options consultation further evidence gathering took place to inform the production of the Draft Plan. In terms of regeneration in the City Centre a number of projects are being delivered e.g. the new Sainsbury’s store opened, the University investment programme continued and work commenced at the Youth Zone and Interchange 10. BCCS Policy CEN3 and Draft Plan Policies CC3(b)(i) and CA2 support new cinema provision in the City Centre, in order to enhance the evening economy and deliver regeneration Wolverhampton needs to successfully fulfil its own role and function within the local, sub-regional and regional area.

7



There are too many discount stores Current evening economy offer needs enhancing Transport issues, such as roadworks elsewhere in the city, dissuade people visiting the city centre

The AAP supports a mix of retail uses in the Shopping Core. Agreed. Policy CC3 seeks to achieve this Whilst temporary roadworks can cause inconvenience, their purpose is to improve infrastructure and accessibility within the city

E Area Action Plan City Centre Reference Group Meeting Tuesday 10th February 2015

Support the overall strategy – it has a sound structure because it provides a focus for different areas, together with flexibility. For example, residential provision in Blakenhall will provide the opportunity for people to live near to where they work Wolverhampton needs a strong manufacturing base (in addition to the Jaguar Land Rover development at i54) in order to provide wealth creation opportunities for small entrepreneurs The Royal Hospital site has been derelict for years and needs a solution. The Royal Hospital would make an excellent location for a museum, particularly focusing on the importance of industry to

Welcomed Agreed. The BCCS employment policies support the provision of high quality employment land, and this is supported further in the adopted Stafford Road Corridor and Bilston Corridor AAPs. The City Centre AAP prioritises the retention of 31ha of employment land which can support manufacturing (Policy CC4). Policy CA11 mentions the potential for community uses at the Royal Hospital development site, which could include a

See proposed changes to Policy CA11 in Appendix (separate document)

8



Wolverhampton’s past and present. Issue of integrated transport needs to be addressed e.g. through new commuter railway station, provision of ‘shuttles’ to the City Centre from outlying areas, a potential ‘sub-regional’ park-and-ride facility in the Black Country. If office provision is focused near transport hubs then commuters will be attracted into the city. Close proximity of shops, cafes and restaurants near to offices will increase the vibrancy of the city centre. If a ‘greater Birmingham authority’ is created then this will divert potential investment away from Wolverhampton to Birmingham

museum. Strategic issues, such as wider transport provision are dealt with through partnership between the Council and other bodies, such as the West Midlands Integrated Transport Authority. The AAP can only deal with sites that are within the AAP boundary, which do include strategic transport sites, such as the Interchange. Policy CC6 addresses effective transport measures which are considered deliverable in the City by 2026. Future strategic transport issues can be dealt with through other planning documents, such as the review of the Black Country Core Strategy. The focus of office provision at the Interchange, together with the strategy to support mixed-use development will help to enhance the vitality and viability of the city centre. Future governance structures fall outside the remit of the AAP. Current sub-regional working, such as the Black Country Local Enterprise Partnership (LEP), has been very successful in securing investment for Wolverhampton.

9



Chapel Ash:

Support the designation of Chapel Ash as a Local Centre (Policy CA5).

The former Eye Infirmary site would lend itself to residential development.

Adequate car parking and signage to car parks is required

The area needs to be made more cycle friendly

Chapel Ash would lend itself to becoming an arts quarter

Future of the Outdoor/ Indoor Market:

Will the Market stay at the current location, and if so will it be smaller than at present?

Do people still need a Market in Wolverhampton City Centre?

The Market still plays an important role for the city, but the image of the

The Market needs to be located closer to the centre of town, such as Dudley Street or St Peter’s Square/ ground floor of the Civic Centre to be close to transport links, car parks and not detached from other elements of the city centre.

Welcomed Agreed. This is reflected in Table CA5A (site ref 5a) See response to ID: G below Enhancing linkages, including for cyclists, is highlighted in Table CA5C The AAP would not prevent arts uses coming forward, for example, in upper floors The future of the Outdoor/ Indoor Market, currently located in the Westside Character Area, is an important issue which will be addressed by the Council in collaboration with interested parties. The Council is committed to the continuation of the market. Policy CA2 and para 4.3.6 emphasises that as part of any future development Westside is still the preferred location for the

See response to ID: G below

10



Other potential sites for the markets could include the former Netto and St George’s Parade stores.

Alternatively, if there is improved accessibility to Westside, a future new multi-storey car park nearby, and a free bus, then the markets could function well in their current location

In response to the increase in online shopping and the rise of empty shops, the city centre would benefit from consolidation in order to focus development, maximise regeneration and increase footfall, together with complementary uses to support a niche retail offer. Infrastructure issues can be partly overcome by encouraging more people to live and work in the city centre. Longer shop opening hours would encourage people to shop after work The city centre needs to be more ‘inclusive’ to attract people with a wide variety of interests. In particular, the leisure offer of the city centre (including the focus on ‘night-clubs’) has worked against other sectors. Therefore, the evening economy needs to be

Markets. Agreed. The overall spatial strategy is to consolidate the retail core to deliver regeneration The AAP encourages residential provision both within the ring road and in surrounding areas. Agreed. Late night shopping is something that does occur in Wolverhampton, particularly in the run-up to Christmas. The AAP is unable to compel shops to extend their opening hours, however a flexible approach to opening hours is encouraged subject to amenity issues. Policy CC3 encourages a variety of evening economy activities, including the provision of a new cinema

11



diversified, particularly encouraging families. Wolverhampton City Centre needs something unique and identifiable to attract new visitors, which should emphasise the ‘experience’ of the city centre – encouraging a friendly environment for people to enjoy. Gateway locations need to be transformed, as has taken place in other cities, such as Birmingham The Canalside Quarter should maximise the potential of the canal by being a focus for leisure and the evening economy presence, and could include e.g. a marina. This area could also become the focus for an urban park Supermarkets, such as Sainsbury’s have the potential

Agreed - the identity and perception of the City Centre is crucial to the future success of Wolverhampton. This requires a collaborative approach. The AAP provides a planning steer to help achieve this – through setting out a positive Vision and having flexible policies to enable future regeneration to deliver qualitative improvements. Agreed. Key gateway corridors (in Fig 6) and frontages (in Fig 8) are identified in the AAP which are a priority for enhancement Policy CA4 and para 4.5.6 promote the enhancement of the canal, public realm and leisure uses (particularly CA4(c)) Policy CA4 requires developments affecting the canal corridor to increase the supply of residential moorings within suitably located and well-managed sites. There is a long term aim to create secure and accessible overnight moorings at Broad Street Basin. Agreed

12



to provide a ‘symbiotic’ relationship with the city centre, especially with provision of several hours free parking to allow for linked trips The importance of providing ‘green areas’ in the city centre from a park, to roof-space Solar Panels should be provided on new multi-storey car parks Support the provision of residential use within the ring road, which could serve to increase the safety of the city centre. Residential provision should include the re-introduction of the ‘urban village’ concept. See also comments by and responses to ID 48 in Table 2 below

Proposals for such uses would be supported. Policy CC10 relates to the provision of Green Roofs Policy CC11 and BCCS Policy ENV7 encourage the use of renewable technology Agreed. Policy CA9 is emphasised as an urban quarter of important character

F Area Action Plan Community Reference Group Meeting Thursday 12th February 2015

Improvements to the environment and public realm are crucial to improving the perception and attractiveness of the City Centre to encourage regeneration Increased and more effective publicity of activities in the city centre is required Issue of Car Parking in Blakenhall Blakenhall would benefit from a greater mix of housing types – particularly larger family homes

Agreed. Policy CC8 seeks to achieve this Publicity is not within the remit of the AAP. See response to 1D 25 under CA10 below Agreed. Policies CC7 and CA10 seek to achieve this

G Wolverhampton Issue of car parking charges It is appreciated that car parking

13



Planning & Building Control Agents Forum Thursday 19th February 2015

Accessibility issues in the City Centre – people who do not drive e.g. need buses to stop near the shops, and the Interchange is remote from the main activities in the City Centre, especially for disabled people.

charges are an issue being raised by stakeholders. Para 1.5.11 recognises Car Parking as a key issue arising from evidence gathering work. It is not within the remit of the AAP to set parking charges. A Car Parking Strategy for the city centre is being undertaken which will cover a number of issues including pricing. The overall proposed approach to car parking is to support an increase in the quality of car parking provision, particularly through multi-storey parking. Bus routes and the location of bus stops are established through partnership working between the Council and other bodies, such as the West Midlands Integrated Transport Authority, Centro and bus operators. Linkages between the Interchange and the rest of the city centre are being promoted, particularly by the works undertaken to Queen Street and through transportation and public realm improvements, which includes facilitating access for disabled people.

14



The potential for regeneration in Chapel Ash is restricted by infrastructure, particularly a lack of car parking provision. Any future parking should be well signposted. There are infrastructure and traffic problems at Walsall Street and Horseley Fields Proposed Metro extension to the Interchange is not ‘consumer led’ to serve the City Centre, it should be

Policy CA5 designates Chapel Ash as a Local Centre. Frontage policy in CA5 would restrict A5 uses, which should help to reduce problems associated with on-street parking. Car parking is provided on Clifton Street. Signage and wayfinding issues have the potential to be addressed through the public realm design guide (para 3.3.6) which is being prepared and could be delivered through other mechanisms such as the work of the Wolverhampton Business Improvement District (BID). Para 4.6.2 highlights that the strategy for Chapel Ash includes strengthening its physical and functional relationship to the core of the city centre. The Sainsbury’s store provides a large quantity of car parking spaces, with a number of hours parking that are free, encouraging linked trips. Policy CC6 identifies the priority for accessibility improvements in this part of the city centre (Ref T8, Fig 5) The proposed Metro extension route has been subject to

15



routed via Market Street Issue of perception of the city centre (poor access/infrastructure, parking and shopping experience) dissuades people from visiting the city centre. What will happen to all the redundant office space in the City Centre? Need more initiatives for redundant buildings to become more sustainable. Owners need incentives to bring units back into use, and the Council needs to co-operate with occupiers to overcome constraints and encourage residential uses above shops

extensive work and consultation, led by the West Midlands Integrated Transport Authority. A partnership approach is being taken to address the strategic transport needs of the City. It is a priority to increase the perception and attractiveness of the city centre, and the AAP strategy as a whole seeks to achieve this. Support will be given to redundant office space being brought into active use, particularly residential (Policy CC7), subject to saved UDP Policy B7 (Policy CC2(b) and (c)). From a planning perspective, bringing units back into use is prioritised by the strategy of consolidating the shopping core, identifying an area for enhancement and refurbishment, introducing a more flexible frontage policy and encouraging the residential use of upper floors.

H Wolverhampton Business Forum Thursday 26th February 2015

A poor image of Wolverhampton city centre is portrayed. The city centre needs to give a more upmarket image if it is to attract investors and create jobs. The Council’s “Making It Happen” brand should be used to develop a vision and plan for the city

Improving the image and perception of the city centre is a key priority. Part A of the AAP sets out a positive Vision for the city centre and how this will be

Para 2.2.1 after “sustainable growth” add “to enhance the image of, and”

16



centre The Council must pursue a car parking charge policy that encourages residents to park in the city centre to shop and encourage investment. With the former Summer Row retail core expansion scheme (in the Southside area of the city centre) and associated Compulsory Purchase Order (CPO) not coming forward, and despite the Council’s Southside Intervention Plan to demolish/ improve shops and provide grants to businesses, all the buildings in the

achieved. In addition, Part C provides a specific vision for each Character Area. The City Centre Prospectus and the AAP use the “Making It Happen” brand It is appreciated that car parking charges are an issue being raised by the business community and other stakeholders. Para 1.5.11 recognises Car Parking as a key issue arising from evidence gathering work. It is not within the remit of the AAP to set parking charges. A Car Parking Strategy for the city centre is being undertaken which will cover a range of issues including pricing. It is recognised that the AAP needs to be deliverable as part of a joined-up, collaborative approach with stakeholders, alongside other delivery mechanisms. The AAP Publication Stage consultation will be supported by a Delivery Plan. Since the decision in 2011 not to enact a CPO and bring forward the Summer Row scheme, the Council has been proactive in enhancing this area through the Southside Intervention Plan. A

Para 1.5.5 add new sentence to end “The AAP is part of a collaborative approach and a comprehensive package of measures to support the sustained regeneration of the city centre.”

17



Summer Row area are of little or no architectural value and are predominantly derelict. The Council should re-invoke their CPOs and flatten the whole area as businesses will rarely invest next to dereliction and the city needs a change in image to attract investors. Main routes into the city have had many long term derelict buildings. Too many derelict buildings have national or local preservation orders. Preservation orders on derelict buildings merely preserve the dereliction. Preservation orders must be deleted to allow development or the Council must fund the viability gap.

number of recent planning permissions such as at the All Nations Christian Centre and for a Casino could bring forward future regeneration. A programme of works to enhance the townscape is underway, and the demolition of a number of buildings has taken place, with the recent announcement that the former Netto building will also be demolished. As set out in para 4.2.5 the AAP supports phased, integrated and sustainable development in Southside and supports public realm and improved linkages. A masterplan will be prepared for Southside. The AAP itself is unable to bring forward CPOs. Future CPOs may be an option that could be explored if they are considered absolutely necessary. The AAP identifies key gateway corridors (Fig 6) and key frontages (Fig 8). A programme is underway for target improvements to key locations in gateways to the city centre. An important element of the AAP is to protect and enhance historic character and local

18



The city centre needs good quality town houses for young professionals and should not be affordable housing. This would mean more people live in the centre and an occupied centre is safer and busier.

distinctiveness (Policy CC9). Buildings which can contribute to achieving this can offer unique opportunities to be successfully brought into economic use. Nationally listed building designations cannot be amended by the Council. Proposals involving alterations to or demolition of listed buildings need to be justified in accordance with relevant legislation, guidance and policies. The determination of individual applications will include giving due weight to the importance of such buildings. The Council has a long and successful record of securing external funding and contributing match-funding for renovation of historic buildings and areas e.g. Molineux Hotel, West Park, Worcester Street, Snow Hill, George Street and the Townscape Heritage Initiative. Policy CC7 supports residential provision in the city centre, and this could include town houses. BCCS Policy HOU3 requires 25% affordable housing on all proposals for 15 or more houses.

19



Wolverhampton needs a vibrant evening economy, and good quality leisure provision, including a multiplex cinema and good quality restaurants, bars and nightclubs, with free convenient car parking at night. Visitors need a safe environment. High-quality brand shops are also needed. Can we believe the AAP will actually happen and will it make any difference? The money due to be spent extending the Metro to the Interchange would be better spent on demolishing empty buildings in the City Centre

Agreed. Policy CC3 and CA2 supports the enhancement of the evening economy, including the provision of a cinema, and para 3.1.13 recognises the importance of providing a safe environment. Policies CC6(d) and CA2(c) support new car parking provision which would particularly assist with enhancing the leisure economy. Please see response above regarding the issue of car parking charges. Policy CC1 supports the provision of a portfolio of retail types and unit sizes (para 3.1.3). The Council has a strong track record of delivering the Wolverhampton Local Plan. The City Centre AAP is of strategic importance and will play a crucial role in facilitating investment, jobs and regeneration in the City Centre. The Metro extension is part of delivering integrated transport, focused at the Interchange, providing infrastructure to support the functioning of the city economy. The funding mechanisms for this cannot be

Para 3.2.15 first sentence after “active” add “, safer” Policy CC1 para 3.1.3, second sentence after “independent” add “high quality brand and speciality” Para 1.5.5 add new sentence to end “The AAP is part of a collaborative approach and a comprehensive package of measures to support the sustained regeneration of the city centre.” See proposed change above

20



The City Centre has declined in recent years and is often empty of people, including many underused car parks (especially in the evening and increasingly at weekends) – people are dissuaded from visiting due to city centre car parking charges and pedestrianisation, together with the attractiveness of other destinations, such as Bentley Bridge Retail Park, Birmingham, Merry Hill and Telford High business rates cause businesses to close

used on other projects The AAP seeks to address the challenges facing the city centre from a planning perspective. This includes increasing the attractiveness of the city centre as a destination by prioritising the consolidation of the retail core (Policy CA1) and supporting complementary uses in the surrounding Character Areas, and through public realm enhancements (Policy CC8). Policy CC6 sets out transport priorities. Please see response above regarding the issue of car parking charges. Works to enhance the pedestrian environment are part of the Council’s Transport and Movement programme, which included extensive consultation with the public and stakeholders It is appreciated that business rates/rents are an issue being raised by the business community and other stakeholders. Business rates/rents is an issue recognised in para 3.5 of the AAP Issues & Options report. It is not within the remit of the AAP to set business

Para 5.1.5 at end of para add new sentence “This requires collaboration with important stakeholders, such as the business community” Para 1.5.3 at the end of the third sentence after “manufacturing base” add “and small and medium enterprises which drive the Wolverhampton economy.”

21



How are the Council consulting on the AAP? Consultation needs to be meaningful and more than just a ‘tick box’ exercise. Big and small businesses feel that they are not being heard by the Council. Speak to the SMEs to understand and appreciate their views and vision. A thorough consultation should be carried out with all businesses (including micro and small) on any proposal that affects businesses. Wolverhampton Business Forum (WBF) will endeavour to help the Council during this process. WBF are willing to support the Council in improving the image and promotion of the City. New proposals and schemes are carried out without concrete evidence or consultation e.g. city centre pedestrianisation, bus lanes, disabled parking, lack of fibre optic broadband in the City Centre

rates. It is recognised that the AAP needs to be deliverable as part of a joined-up, collaborative approach with stakeholders, alongside other delivery mechanisms. The AAP Publication Stage consultation will be supported by a Delivery Plan. Extensive consultation on the AAP has taken many forms and is set out in the Consultation Report. Businesses are recognised as really important stakeholders, as acknowledged in para 1.5.9. The preparation of the AAP is a transparent process and planning officers have been proactive in engaging with the business community in the preparation of the Local Plan and are committed to continuing this on an on-going basis. Welcomed Pedestrianisation and other traffic and highways measures are part of the Council’s Transport and Movement programme, which included extensive consultation with the public and stakeholders.

Para 1.5.7 after “to develop the office and service sector role of the city centre” add “, support businesses”

22



Roller shutters on shops should be of one standard type. During the day all shutters should be up to avoid portraying a bad image of the city. The work of Darlington Street Methodist Church is meeting a desperate need in providing food for those in need, but this service should be provided inside the church, and not affect the image of the city centre. Disappointed by attractiveness of Wolverhampton to SMEs. The AAP needs to serve small and medium-sized businesses, not just attract large multiple retailers. The AAP does not have policies that address

Regarding fibre-optic broadband it is not within the remit of the AAP to require such provision, however WCC are working with partners to deliver improvements to connectivity, including promotion of broadband voucher scheme and exploring options through social value and letting concessions. The AAP is unable to alter existing planning permissions for roller shutters. The Council takes a proactive approach to appropriate roller shutter design and placement under current policy and guidance. The important role played by the Little Brothers of the Good Shepherd at Darlington Street Methodist Church is recognised in para 1.5.9, and is supported by the Council. The precise way in which this service is provided at the church is not within the remit of the AAP. Businesses are recognised as really important stakeholders, as acknowledged in para 1.5.9. Agree that a portfolio of business

See proposed changes above

23



the issues faced by SMEs like parking costs, integrated transport that works for both businesses and their links to communities. Is the AAP ambitious enough? There is a lack of really bold visionary goals for the next 30 to 50 years. The Council must work with partners to develop a clear vision for the City. The AAP is not fit for purpose to enable us to compete primarily with Birmingham. Need to plan against where Wolverhampton’s areas of competitive advantage will be, rather than plan to

sizes should be promoted that can complement one another (e.g. in retail terms see para 3.1.3). Please see response to car parking issues above. Policy CC6 and CA3 address integrated transport issues, in particular the promotion of the City Interchange. In order to be effective the AAP needs to be both aspirational and realistically deliverable. The AAP seeks to achieve this balance by setting out an ambitious and forward-looking Vision to 2026, together with setting out objectives, a strategy and outputs (Part A), supported by policies to deliver the strategy for regeneration (Parts B and C). The AAP sets out a clear strategy to deliver regeneration in the city centre, and sits within a wider strategy of the Wolverhampton Local Plan and the BCCS. Wolverhampton needs to successfully fulfil its own role and function within the local, sub-regional and regional area. The AAP needs to achieve both the effective resolution of current

24



resolve current issues as a way to move us forward.

planning issues and facilitate the transformation of the economy to capitalise on future areas of competitive advantage. The AAP seeks to achieve this by promoting flexible mixed-use development, which includes diversifying the economy, through Grade A office provision, retained employment land, consolidation of the retail core and encouraging leisure uses, supported by an increased resident population. This approach is complemented by strategies elsewhere in the city, e.g. the adopted Stafford Road AAP focuses on supporting the provision of high quality employment land, including advanced manufacturing.

I Wolverhampton Women’s Business Forum Tuesday 10th March 2015

The City needs to attract small businesses, not just large anchor stores Issue of Car Parking charges

Agreed. Not only would the attraction of large anchor stores increase the likelihood of supporting smaller businesses through linked trips, but the strategy to consolidate the retail core, increase flexibility and encourage complementary uses is aimed at attracting a mix of businesses to the city centre. It is appreciated that car parking

Para 1.5.3 at the end of the third sentence after “manufacturing base” add “and small and medium enterprises which drive the Wolverhampton economy.

25



charges are an issue being raised by the business community and other stakeholders. Para 1.5.11 recognises Car Parking as a key issue arising from evidence gathering work. It is not within the remit of the AAP to set parking charges. A Car Parking Strategy is being undertaken for the city centre which will cover a number of issues including pricing.

J Wolverhampton Community Action Network Meeting Thursday 12th March 2015

Discussion about location of the indoor/outdoor market – various views on where it could be best located and what factors are crucial to its success (such as location, levels of rents, quality, proximity to transport links) Work needs to focus on improving the environment of the city centre Concern about the new owners of the Mander Centre which could lead to increased rents and prices

The future of the Outdoor/ Indoor Market, currently located in the Westside Character Area, is an important issue which will be addressed by the Council in collaboration with interested parties. The Council is committed to the continuation of the market. Policy CA2 and para 4.3.6 emphasises that as part of any future development Westside is still the preferred location for the Markets. Agreed. Policy CC8 seeks to achieve this and para 3.3.6 emphasises that a public realm design guide will be prepared. The setting of rents and prices are not within the remit of the AAP. The proposed

26



Compliment the AAP preparation and consultation process, including the Draft Plan leaflet

reconfiguration of the Mander Centre will provide investment, regeneration and jobs to the city centre, including enhancing the vitality and viability of the city centre Welcomed

K Wolverhampton Black Business Network Meeting Tuesday 31st March 2015

The network welcomed being kept informed of, and engage with, the AAP preparation process Issue of Car Parking charges The need for an enhanced evening economy offer Importance if improving infrastructure in the city centre, particularly connectivity such as free wi-fi and broadband to retain existing businesses and attract new businesses

Welcomed. It is appreciated that car parking charges are an issue being raised by the business community and other stakeholders. Para 1.5.11 recognises Car Parking as a key issue arising from evidence gathering work. It is not within the remit of the AAP to set parking charges. A Car Parking Strategy for the city centre is being undertaken which will cover a number of issues including pricing. Agreed. Policy CC3 seeks to achieve this. Agreed. It is not within the remit of the AAP to require such provision, however WCC are working with partners to deliver improvements to connectivity, including promotion of broadband voucher

27



scheme and exploring options through social value and letting concessions.

Table 2: Formal Consultation Responses (full respondent comments are available on request)

General

ID Respondent Summary of Respondent Comments Council Response Proposed Change to Draft Plan

1 The Coal Authority No comment None

2 West Midlands Police Authority (Tyler Parkes)

Theme of community safety should be included within the Vision and considered in all aspects of policy formulation.

The first sentence of the Vision refers to creation of a “safe” city centre. Community safety underpins the BCCS and was a factor in formulating policy, as reflected in Policy CC8: High Quality Design & Public Realm.

3 Natural England Natural England has no objection to the Draft City Centre AAP in respect of Cannock Chase SAC impacts or impacts on other European Sites. The draft AAP in general addresses the natural environment well, including the need to ensure enhancement and protection of environmental assets and to promote environmental infrastructure, which are reflected in the vision, spatial strategy and key drivers. However, the poor quality of existing environmental

Noted Welcomed The need to improve the quality

Amend para 1.5.11 to: “…

28


infrastructure in the area should be identified as a key issue and improvement / creation of EI included / quantified in the key development outputs.

of and linkages between environmental infrastructure assets has been identified through a range of evidence and this should be reflected as a key issue and in the key outputs. It is difficult to quantify such improvements - where this is possible it has been included in Part C.

Historic Character Environmental Infrastructure ….

Existing environmental infrastructure is fragmented and under-used”

Amend para 2.4.1: “…

An accessible network of high quality environmental infrastructure.”

4 Historic England (English Heritage)

Support references to historic character, local distinctiveness and need to protect important buildings on page 12 and in the Vision/Spatial Strategy, and the character area approach and use of characterisation studies to inform the Plan. Recommend amending para 2.2.1 and other para’s throughout the document to read protecting and conserving rather than preserving. As a number of heritage assets and archaeological sites may be affected by development opportunities the potential impacts on the historic environment should be assessed using the evidence base and any issues raised and necessary mitigation covered in Part C.

Welcomed It is considered appropriate to use the term “preserve” as this is used in the relevant legislation. Agree that the details provided for each development opportunity in the tables in Part C should reflect a high level evaluation of any historic environment constraints and opportunities, including the potential effects on views of landmark buildings and the proposed designation of historic landscape

Add new paragraph after para 3.3.18: “The historic character and local distinctiveness factors to be taken into account for each development opportunity, including archaeological potential, are highlighted in Part C. Where there is potential

29


characterisation sites. Further work has been undertaken to check and standardise the approach across all Character Areas and regarding potential archaeology for development opportunities using information held in the Wolverhampton Historic Environment Record and available historic map sequence, which will be reflected in appropriate changes to Part C.

for archaeological deposits to be present, in accordance with UDP policies, a detailed desk-based assessment will be required, and potentially evaluation, excavation or a watching brief if preservation in situ is not possible.” Various changes to Part C (see below)

7 West Midlands Integrated Transport Authority (Centro)

Supportive of the overall aims and objectives and design and transport proposals in the AAP.

Welcomed

8 Highways England (Highways Agency)

The overall level of development proposed in the AAP is consistent with the BCCS. The City Centre is the most sustainable location for development in the City and opportunities for development should therefore be maximised. The focus on mixed use development in many Character Areas will optimise scope for linked trips and integrated routes.

Welcomed

9 Royal Wolverhampton NHS Trust

Fully support the aims of the AAP to increase economic and development activity.

Welcomed

10 Sandwell MBC Support for the draft AAP. Welcomed

11 Walsall MBC Support for the draft AAP Welcomed

12 South Staffordshire Council

Support for the draft AAP Welcomed

13 University of Wolverhampton

The University of Wolverhampton is generally supportive of the AAP. Please ensure the document refers to ‘University of Wolverhampton’ throughout.

Welcomed

Change references to the ‘University of Wolverhampton’

30


Para 2.2.1 - pleased that the AAP recognises the importance of education uses in delivering a more prosperous city centre economy. Para 2.4.1 - welcome aim to deliver 18,000 sqm of new education floorspace, of which at least 12,000 sqm at the Springfield Campus (including the University and WMCUTC) is an important element.

Welcomed Welcomed

14 City of Wolverhampton College

Support for the draft AAP it would be good to give the project to create a new city centre campus some prominence

Welcomed Noted. This project is referenced in Policy CC5(iii), and support is given to education uses both in this policy and in site specific policies of the AAP (Part C). As a specific site for the campus is yet to be identified it is difficult to add any further detail at this stage.

15 British Telecommunications Plc

Importance of ‘connectivity’ to support the re-vitalisation of the city centre, including wireless (e.g. Wi-Fi) connectivity

Noted. It is not within the remit of the AAP to require such provision, however WCC are working with partners to deliver improvements to connectivity, including promotion of broadband voucher scheme and exploring options through social value and letting concessions.

16 Woodland Trust Pleased that incorporation of street trees and woodland in new development and safeguarding open spaces are referenced in the Draft Plan. However, there should be more references to the benefits of trees and woodland throughout the AAP, as woodland helps to deliver public health

Noted. Natural green space, woodland and trees are sufficiently covered in BCCS and UDP policies, including UDP Policy N7: The Urban Forest. Therefore, it is sufficient to

31


improvements. Space for People and the Woodland Access Standard should be used to evidence need for woodland in Wolverhampton.

promote street trees and woodland in one policy in the AAP - there is no merit in repetition. The Open Space Sport and Recreation SPD, adopted in 2014, sets out current local standards for open space (including natural green space) in Wolverhampton, which are realistic and deliverable – these form the evidence base for the AAP.

17 Council for British Archaeology West Midlands

The Draft AAP recognises the importance of the City’s history, strong identity and rich and distinctive character and will enable a sense of place to form the heart of sustainable regeneration. The AAP further embeds Wolverhampton’s strong track record in heritage-led regeneration, being well-informed by the HLC and Viewshed studies and providing a clear commitment to protect the historic environment and heritage assets, bring listed buildings back into use, protect local character and promote cultural heritage.

Welcomed

19 The Victorian Society

Support the vision, objectives, design and historic environment elements of the Plan, including Policy CC9, use of Historic Landscape Characterisation and Viewsheds study and principle to conserve and enhance heritage assets through sensitive development and environmental improvement.

Welcomed

20 Wolverhampton & District Society of Architects

Support aim of attracting investment and enhancing prosperity and well-being of people in Wolverhampton, and vision and objectives.

Welcomed. The Delivery Plan provides details regarding the delivery of key AAP proposals.

32


However, the AAP lacks focus and delivery.

21 Wolverhampton Civic & Historical Society

Welcome the AAP, in particular the vision and historic environment references. However, Wolverhampton should learn from the ABCD legacy and regeneration experience of similar Cities. Also question deliverability given this is a long term plan of high aspirations with no dedicated budget, and the Character Area approach could lead to a piecemeal rather than unified approach to regeneration. Welcome inclusion of Dudley Road Schools complex (as a community hub and heritage asset) and St Luke’s Church (which is likely to become a “building at risk”) into the AAP area.

Noted. The ABCD legacy of environmental improvements, housing renewal and community involvement is fully reflected in the AAP. The Council and partners are committed to comprehensive City Centre regeneration as a top priority. This approach has involved the careful prioritisation of certain sites and areas for investment, both public and private sector, and securing external funding. Details are set out in the Delivery Plan. Noted.

24 Black Country Touring

Surprised to see that the suggested Boundary plan for the City Centre AAP did not include the Newhampton Arts Centre (NAC), which is very close to the edge of the current boundary. It is a dynamic and highly active site of cultural activity serving both the local and wider community and I feel it would be both of benefit to both the city centre’s cultural offer and the Centre itself to be included within the boundary. The NAC aligns to both Policy CC3, Leisure, Visitor and Cultural Facilities and Key Driver 2 Creating

See response to ID 41 below See response to ID 41 below

33


Sustainable Communities. Through work with the Black Country Touring arts organisation the NAC plays a vital role in ensuring local communities have access to high quality arts activities and it makes a very different and important contribution to Wolverhampton’s cultural offer with family friendly, affordable activity. It provides a well equipped professional venue which is different to and is a valuable addition to the current range of venues that the city centre has to offer. Currently the only other dedicated small scale theatre venue in the city centre is the Arena Theatre.

26 Tesco (Nathaniel Lichfield & Partners)

Tesco welcome the consultation and are keen to play a role in the regeneration of the City Centre. Support the AAP Vision and suggest the Royal Hospital Site and former Bus Depot (Site 11a Policy CA11) will contribute to achieving the Vision.

Welcomed

29 Conygar Investment Company (Savills)

Para 1.5.11 – support encouragement of strong leisure offer in Bullet 2 Para 1.5.11 – support recognition of the need for promoting mixed-use development and provide flexibility to changing market conditions, as noted in Bullet 3. Para 1.5.11 - suggest Bullet 2 be amended to reflect the conclusions of the Retail Update Study para 7.34 that peripheral retail areas would still continue to perform their established retail role in the future.

Welcomed Welcomed Noted. It is not felt appropriate to include this specific observation in the broad strategic issues that are set out in para 1.5.11. See response to ID 29 under Appendix E below

34


Fig 3 shows different development opportunity boundaries to Figure 11

Noted. Fig 3 is a three-dimensional representation of the City Centre, indicating the location of development opportunities, where surface levels are highlighted in red. This means that built-structures obscure the red highlighted areas. These images are not used for site-specific policy purposes - Fig 11 and detailed Character Area figures such as Fig 15 provides the definitive site-specific boundaries and proposals.

33 Horton Estates Ltd Having a Plan and strategy is a great start and I support the approach. What Wolverhampton needs to be is a City that attracts its people in to the centre to work and play. This is lacking at the moment, but there is a desire to change that perception. This takes time but this is starting.

Welcomed

34 LCP Properties Ltd (Turley)

A robust strategy is needed to regenerate and revitalise the City Centre and LCP is encouraged that an AAP is being prepared to support this. The AAP provides the opportunity to establish a strong planning framework for the future of the City Centre, based on a credible evidence base and engagement with key landowners and investors Proposals for retail development in edge and out of centre locations must still be subject to the sequential and impact tests as set out in NPPF para 25 & 26. To ensure there is no significant adverse

Welcomed Policy CC1(f) does set out these requirements, and the first column of the Development Opportunities Tables that form

35


impact on the vitality and viability of the City Centre. This should be made clear particularly in Policies CA2-11

part of Policies CA2-11 cross reference other relevant policies, which include Policy CC1

36 Peel Land and Property (NJL Consulting)

Para 2.4.1 – welcome the key development outputs would give the flexibility enable either of the latest consents at The Peel Centre to be built out, optimising the potential to bring visual and economic benefits to the surrounding area

Welcomed

39 Resident Need to increase the vitality and vibrancy of Wolverhampton city centre and the appeal of the town to outside investors and businesses. Too many people are going to Telford and Merry Hill because of parking and convenience. Wolverhampton needs to encourage these people back by vastly improving the retail offer and free car parking would give the town a big boost.

Noted. Parking charges are not within the remit of the AAP.

40 Newhampton Arts Centre

The AAP boundary misses out Newhampton Arts Centre (NAC) even though it is less than 10 mins walk to the city centre and borders both the Molineux and the West Park quarters The pedestrian access to NAC could be improved with the crossings on Waterloo Road and the university underpass. Plans for the Molineux Quarter include leisure facilities with students in mind, something Newhampton Arts Centre can and do contribute to. Conservation of historic buildings is a theme in the overall plan and NAC is marked as a locally listed building, but not included.

See response to ID 41 below See response to ID 41 below

36


Since the funding cut from Wolverhampton City Council, Newhampton Arts Centre is actively engaged in increasing income streams and pursuing funding including Heritage Lottery Funding to improve the buildings. This would be easier if the area was part of the city plan. The friends group set up to help Newhampton Arts Centre survive in these difficult times feel that there is a complete lack of interest from Wolverhampton City Council which is reflected in this plan. Efforts appear to be put into promoting the new youth zone being built and ignoring the facilities that already exist at NAC for many of these activities such as dance studios, rehearsal spaces and the performance theatre.

41 Newhampton Arts Centre Board

It is vital for the Newhampton Arts Centre (NAC) and for the cultural offer the City that the NAC are part of the AAP. NAC forms a logical geographical and cultural link between the West Park/ Chapel Ash areas and Molineux/University areas. The NAC is a city-wide resource, as well as being strongly rooted in the community of Whitmore Reans, provides artistic, cultural and community space which needs to be seen as a key link between the environmental and sporting provision on this side of the city centre. The NAC is located in very close proximity to the city centre being 10mins walk from the Civic Centre and well serviced by buses. Pedestrian access would be improved by the proposed improvements to Waterloo Road and University underpass. NAC is situated

The City Centre AAP boundary specifically reflects two strategic areas of change identified in the adopted BCCS – notably Wolverhampton Strategic Centre (SC4 – BCCS Appendix 2 pp. 18 – 25) and Regeneration Corridor 3 (RC3 – BCCS Appendix 2 pp. 37 – 40), which therefore would benefit from having an AAP to help steer regeneration. This is the consistent approach that the Council have used when bringing forward all AAPs as part of the Wolverhampton Local Plan (with the adopted Stafford Road Corridor AAP covering BCCS regeneration corridors RC1 and

37


right next to Molineux Alley which could form a key pedestrian and cycling route in and out of the city centre (a study has already been undertaken) Development of the adjacent Molineux Quarter is proposed to include provision for students, something the NAC already contributes towards and has plans for greater involvement The NAC can support a number of AAP policies including developing existing leisure and cultural facilities and preserving the historic buildings (CC3a and CC9) NAC is actively engaged in increasing income streams and pursuing funding, including Heritage Lottery Funding to improve the buildings, working with the College and officers from the council. Being situated within the AAP area would strengthen applications for funding

2; and the adopted Bilston Corridor AAP covering BCCS regeneration corridor RC4). Consideration was given to making adjustments to the AAP boundary following consultation on the Issues & Options stage (December 2013 – January 2014) in preparation of the Draft Plan. Whilst some minor adjustments to the AAP might be appropriate, in order to include the Newhampton Arts Centre (NAC) within the City Centre AAP, the boundary (set out by BCCS SC4 and reflective of the saved UDP City Centre inset map) would have to be significantly redrawn. This would bring within the AAP a predominantly residential area which is part of the community of Whitmore Reans that, whilst it does have some links to the City Centre, does not function as part of the City Centre itself. WCC appreciates and recognises the important role and function played by the NAC, and the role it plays in complementing other cultural, community and leisure uses in this part of the city. However, an effective

38


planning framework already exists for areas that do not fall within AAP boundaries through the BCCS and saved policies of the Wolverhampton Unitary Development Plan (UDP, June 2006), together with the NPPF. For example, the NAC is already protected as a local listed building within a Conservation Area, and saved UDP Policy C3 – Community Meeting Places, would apply to any future proposals involving the loss of facilities at the NAC. Future improvements to pedestrian access which would benefit NAC are already identified in the AAP (see Fig 5 refs T3 and T5). Additional pedestrian enhancements, such as improvements to Molineux Alley could be explored in liaison with Transportation. Whilst not falling within the City Centre AAP this would not prevent NAC seeking to increase income streams and pursuing funding including Heritage Lottery Funding. The AAP is subject to on-going Equality Impact Analysis. For the reasons set out above there is an

39


existing framework in place which can address equality issues from a planning perspective (the BCCS); and future mechanisms are available if the community wish to pursued them (e.g. Neighbourhood Plans).

42 Rock School As users of the Newhampton Arts Centre (NAC), we note with concern that the NAC is not included in the City Centre Plan:

NAC forms a geographical and cultural link between the West Park/Chapel Ash areas and the Molineux/University areas. The Centre, provides artistic, cultural and community space. It seems perverse for the boundary to skirt NAC.

NAC is located in very close proximity to the city centre being ten minutes’ walk from the Civic Centre and well serviced by buses.

NAC is actively engaged in increasing income streams and pursuing funding including Heritage Lottery Funding to improve and sustain the site and the historic buildings. Being situated in the development area would strengthen applications for funding.

NAC could support and benefit from a number of key policy proposals in the plan:

o The development of the adjacent Molineux Quarter is proposed to include leisure provision for students something that NAC is already contributing towards and has plans for

See response to ID 41 above See response to ID 41 above

40


greater involvement. (CA7) o Pedestrian and cycling access to the

centre would be improved as a result of the proposed changes to the Waterloo road junction and the University underpass, which could be extended to Molineux Alley. (CC8)

o The NAC provides a significant existing leisure and cultural facility. (CC3a)

o It is a historic Victorian building and locally listed, close to the historic West Park (CC9)

We propose that the boundary be adjusted to include the Newhampton Arts Centre in the City Centre Plan.

43 Yoga Zone As a regular user of Newhampton Arts Centre (NAC) we note with concern that the NAC is not included in the City Centre Plan. Prior to 'finding' the NAC venue, we had struggled for 3-4 years to find a suitable venue from which to offer what we consider to be a very valuable Leisure service to Wolverhampton residents. Venues for Yoga classes are notoriously difficult to find as they need to be quiet, warm, clean and uncluttered, referrably carpeted as well as having adequate parking facilities available.

NAC forms a geographical and cultural link between the West Park/Chapel Ash areas and the Molineux/University areas. The Centre, provides artistic, cultural and community space. It seems perverse for the boundary to skirt NAC.

NAC is located in very close proximity to the


41


city centre being ten minutes walk from the Civic Centre and well serviced by buses.

NAC is actively engaged in increasing income streams and pursuing funding including Heritage Lottery Funding to improve and sustain the site and the historic buildings. Being situated in the development area would strengthen applications for funding.

NAC could support and benefit from a number of key policy proposals in the plan:

The development of the adjacent Molineux Quarter is proposed to include leisure provision for students something that NAC is already contributing towards and has plans for greater involvement. (CA7)

Pedestrian and cycling access to the centre would be improved as a result of the proposed changes to the Waterloo road junction and the University underpass, which could be extended to Molineux Alley. (CC8)

The NAC provides a significant existing leisure and cultural facility. (CC3a)

It is a historic Victorian building and locally listed, close to the historic West Park (CC9)

We propose that the boundary be adjusted to include the Newhampton Arts Centre in the City Centre Plan.

44 Resident The document is unwieldy and too heavy. Wish to compliment efforts to regenerate the Centre of the town particularly within the Ring Road.

The AAP has been reduced to the minimum size necessary to set out and explain the proposals and policies. Welcomed

42


Wolverhampton streets need to be more accessible to a resident city centre population. More empty inner city offices and retail space are not needed in the St Peters area. Car parking needs to be protected and more accessible social housing provided with appropriate facilities to encourage inner city living. Suggest survey of retail building upper floors regarding potential for residential and opening up to the back onto main roads. An architectural competition would produce a range of ideas on how the centre of the town can be made to become livelier again. The conversion of St George’s Church to a supermarket represented planning blight. Efforts should be paid first to marketing the derelict area of the central zone before any further changes on this scale are undertaken The area around the Market place is in desperate need of a free Market each weekend to liven up the

Noted, the AAP seeks to ensure no net loss of parking spaces across the AAP area. Some car parks are identified as development opportunities that could come forward for development over the length of the plan period in order to achieve the aims of the AAP A Car Parking Strategy for the City Centre is being undertaken which will cover a number of issues including pricing. Parking charges are not within the remit of the AAP.[see also response to ID 31 under Policy CA8 below] Work has been undertaken to look at the potential of upper floors within the City Centre core area, and this has helped to generate potential housing conversion figures. St George’s now has an established use as a supermarket and the AAP promotes flexible re-use which retains the building. The AAP supports retention of the Market. Market rents are

See response to ID 31 under Policy CA8 below

43


town. Business people who migrate their businesses to other local towns inform me their move was prompted by both the cost of short term leases and of ever unaffordable rates as footfalls diminish every week.

outside the remit of the AAP.

45 Resident Do not object to the Plan’s proposals and principles, but the boundary should be extended to include the Newhampton Arts Centre (NAC), Newhampton Road, an adjoining important building and facility. NAC lies close to the ring road between the Molineux Quarter and the West Park Quarter but it is not included in either. Conservation of historic buildings is a theme in the overall plan (Policy CC9) and NAC is marked as a locally listed building, but not included. This building has facilities which could be used to deliver and enhance some of the proposals in the plan, for example leisure facilities, including those designed with students from the University in mind. There is already a drama studio and rooms suitable for a variety of community uses e.g. for choirs, art groups, meetings, etc. which would support Policy CC3. As it was formerly a school there are facilities for educational use (2.4.1, Policy CC5) and areas could be developed for office space (para 2.4.1) There is also a café and an antiques outlet. It would be possible to provide areas for other specialist retail outlets.


46 Resident Generally support the plan but boundary looks odd as in the south east the area between the A454 Willenhall Road and the A41 Bilston Road is excluded although this includes the Birmingham Canal, East Park, Monmore Green Stadium and the fruit and vegetable market.

The area referred to forms part of the Bilston Corridor AAP as it relates more closely to the Bilston Corridor, and cannot be covered by two AAPs.

44


As the Newhampton Road is a principle access road/gateway this seems odd. Again, perhaps a boundary roughly following the postcode boundary from West Park along Leicester Street and Dunstall Road to Fiveways would make more sense - filling the gap. As the plan mentions the Equality Duty one would think including this chunk of Whitmore Reans (culturally diverse and suffering a degree of deprivation) would contribute towards meeting that duty. In terms of heritage this area also includes the renovated former barracks on Newhampton Road (now flats), the Sikh temple which has renovated adjacent buildings to bring them back into use and the Newhampton Arts Centre which has taken over management, and aims to develop the listed Victorian building vacated by Wolverhampton College and the rest of the site.

See response to ID 41 above


47 Resident The boundaries of the Molineux – or perhaps the Chapel Ash and West Park – area should be expanded to include the Newhampton Arts Centre in Dunkley Street. This is a valuable and much valued resource to the city, providing activities and opportunities that are not available elsewhere. There is a great danger to its continued/long term existence if it is not included in an AAP. Being situated just outside the ring road, it tends to get ignored by both WCC and the general public, but is only a ten minute walk from the city centre, and two or three minutes from both Molineux and West Park. Improvements in pedestrian access would greatly



45


help, making it easier to cross Waterloo Road, for example, or enhancing the route that goes St Peter’s – underpass – Molinuex Hotel – football ground – Molineux Alley. There would be great symbolic advantage to the arts centre in being included in the AAP, when funding from outside bodies is being sought. The fact that the building is locally listed suggests that it should be included.

48 Our Own Future The overall AAP approach is fine - open to suggestions and modifications but still with a sensible approach. It would be good to have certain areas designated for different themes rather than everything scattered around with no cohesion. I think there is a good possibility of creating more jobs within each zone by making them as all-encompassing as possible, e.g. in a office zone, having shops and cafés so that the workers can easily get what they want during lunchtimes and after work.

Welcomed Noted. This is exactly what the proposed spatial approach seeks to achieve, with each Character Area having certain lead uses e.g. retail in the Shopping Core; leisure at Westside; and Offices at the Interchange, supported by complementary mixed use development which could include e.g. certain shops and cafes

50 Resident Graffiti in the subways under the ring road is intimidating and makes for a very unfriendly environment. Some “street art” can be attractive.

Noted. Graffiti issues fall outside the remit of the AAP and are dealt with by the Council Street Scene services.

51 Howling Wolves Community Choir

As users of the Newhampton Arts Centre (NAC) wote with concern that the NAC is not included in the AAP. NAC forms a geographical and cultural link between the West Park/ Chapel Ash areas and Molineux/University areas. The NAC provides artistic, cultural and community space.


46


The NAC is located in very close proximity to the city centre being 10mins walk from the Civic Centre and well serviced by buses. NAC is actively engaged in increasing income streams and pursuing funding, including Heritage Lottery Funding to improve and sustain the site and the historic buildings. Being situation within the AAP area would strengthen applications for funding. NAC could support and benefit from a number of key policy proposals in the AAP:

Development of the adjacent Molineux Quarter is proposed to include provision for students, something the NAC already contributes towards and has plans for greater involvement (CA7)

Pedestrian and cycling access would be improved by proposed improvements to Waterloo Road and University underpass which could be extended to Molineux Alley (CC8)

The NAC provides a significant leisure and cultural facility (CC3a)

NAC is a historic locally listed Victorian building, in close proximity to West Park (CC9)

52 Resident Heartened that Wolverhampton has an action plan – many innovative ideas. Please look at simple, initial things regarding litter and general cleanliness in the city centre and beyond.

Welcomed. Litter and cleanliness issues fall outside the remit of the AAP and are dealt with by the Council Street Scene services.

56 Resident Suggested additions to para 1.5.2, 1.5.3 and 1.5.9 to include reference to Wolverhampton’s historic

Noted. The historical background of Wolverhampton was

See change ref 13 in Table 3 below.

47


development, religious function and churches, and typographic corrections.

extensively set out in para 1.19 of the Issues & Options Report. This text has been condensed to ensure the AAP as a working planning document is as concise as possible.

Second sentence of para 1.5.3 after “cultural” add “religious”, and after “theatres” add “places of worship” Add to end of para 1.5.9 “,and places of worship.”

48

Policy CC1 Meeting Shopping Needs



The proposed approach to renewal and growth in the core area is constrained but realistic. However a sharper focus is needed to deliver the new retail /mixed use hub at Cleveland St / Temple St linked to the Wulfrun Centre (1(b)). Concern that the AAP states superstores are over-trading and justifies permissions granted for three superstores which would be in competition with City Centre Core Area retailers. However Sainsbury’s is under-trading and the stores with permission at Royal Hospital and Peel Centre are unlikely to be delivered. The retail policy should be reviewed to take into account changing retail patterns.

Noted. The delivery of the new retail / mixed use hub is one of the Council’s key delivery priorities, as set out in the Delivery Plan. The Retail Update Study suggests that there is some over-trading in superstores over all, taking into account changing retail patterns.


The emphasis on improving shops is unachievable given on-line shopping impacts and the low range and quality of the current offer.

The policy is supported by a robust Retail Update Study which takes into account recent and projected changes to shopping patterns.

30 Blue Square Penn Road Ltd

Welcome vision however there is a potential conflict between creation of residential communities and retention of important local employment land.

Noted. Agree that a balance needs to be kept between retaining local employment land and providing new housing.

28 Benson Elliot (DPP Planning)

Welcome the emphasis placed on the Primary Shopping Area (PSA) and proposals for the Mander Centre. Given the changing nature of retailing, concern about potential alternative comparison retail uses coming forward at sites with permission for large-scale foodstores (The Royal Hospital and The Peel

Welcomed The retail uses for The Royal Hospital (Site 12a in Policy CA11) and The Peel Centre (Site 4b in Policy CA4)

49


Centre). Policy CC1(f) could be reinforced by making specific reference to the inappropriateness of development in these locations which could prejudice the delivery of comparison goods investment in the PSA

represent consented or implemented retail schemes. The Peel Centre non-food permission would involve a reconfiguration and extension to the existing retail park location. It would be too specific to mention The Royal Hospital and The Peel Centre in Policy CC1(f). CC1(f) is sufficiently detailed and robust to ensure that any potential impacts on investment in the PSA are thoroughly considered. Policies CA4 and CA11 (see Appendix – separate document) provide more detailed guidance about these sites

33 Hortons Estates Ltd Retailing in Wolverhampton is not just about the Mander Centre. There are other elements that go on there as well, including the traditional retail areas of Dudley Street for example. Support of independent retailers is needed as they add valuable choice and interest in a city centre, and with the support of the Council which could include the reduction in business rates for example, that would help.

Noted. Business rates are outside the remit of the AAP.


Welcome the Council’s desire to see the regeneration of the existing shopping core The AAP needs to allow for and encourage the revitalisation and attraction of investment in to the Shopping Core first, before new development can be

Welcomed Agreed

50


considered acceptable in other locations. The Retail Update Study (paras 7.27 & 7.30) identifies an overprovision of retail floorspace at the present time and only limited capacity for new floorspace later in the plan period. Existing City Centre retail trading is delicate and new retail development outside the shopping core could discourage investment and footfall. Policy CC1 should be updated to ensure the priority that is given to the shopping core and the timing of the delivery of new floorspace is clear Proposals for retail development in edge and out of centre locations must still be subject to the sequential and impact tests as set out in NPPF para 25 & 26. To ensure there is no significant adverse impact on the vitality and viability of the City Centre. This should be made clear in Policy CC1(f)

This is acknowledged and reflected in Policy CC1, with CC1(c) focusing retail provision within the PSA, and highlighting that Southside could provide new retail floorspace later in the plan period. CC1(e) sets out that any retail proposals outside the PSA should be complementary and not prejudice or delay the priorities for the “area for enhancement and refurbishment” in the Shopping Core Policy CC1(f) does set out these requirements. Consistent with the approach in the BCCS, the AAP is ‘future-proofed’ by referring to “relevant national planning policy”, which is currently NPPF paras 25 & 26. The BCCS and NPPF requirements are explained further in supporting para 3.1.7 of Policy CC1


Welcome reference to the potential to provide a foodstore at The Peel Centre in policy CC1(d) Note that there is no mention of the Peel Centre’s ability to meet large-scale non-food development of

Welcomed Policy CC1 sets out the overall retail strategy and the detail for

51


the type to accommodate business models that cannot be readily accommodated within City Centres. If the future of the Peel Centre is to be secured and maximum benefit brought to the Stafford Road Corridor then the site’s potential to deliver a range of retail types needs to be recognised an supported positively (as it appears to be within Policy CA4). It is important that the site’s future retail offer is not narrowed so far as to restrict its ability to attract occupiers. As no reference is made to the Peel Centre’s non-food retail capabilities in Part C of Policy CC1, under the requirements of para 3.1.7 any proposals for additional floorspace over 200sqm would have to meet the requirements of Core Strategy Policy CEN7, which requires a sequential test to be carried out and says “it is not accepted that specific classes of goods cannot be sold from in-centre locations. Developments would need to demonstrate flexibility in their operational requirements in terms of format”. This statement has been superseded by and is not consistent with recent court and appeal decisions and is now effectively out of date Remove reference to The Royal Hospital in para 3.1.5 as it has been publicly announced they will not be bringing forward the Royal Hospital Site themselves. Suggest rewording “This could be provided by a foodstore at The Peel Centre, and an additional foodstore at The Royal Hospital Site”

appropriate uses in individual development opportunities is set out in Part C of the AAP Whilst National Planning Policy Guidance (NPPG) for “Ensuring the vitality of town centres” para 010 on the sequential test does refer to flexibility, including in terms of format, due weight will be given to all aspects of Local Plan policies in the light of latest interpretations of how policies should be applied. Para 3.1.7 refers to “relevant” BCCS requirements. Noted.

Policy CC1(f) add “relevant” before “requirements” In light of the announcement by Tesco on 8th January 2015 that they will not be proceeding with delivering a foodstore at The Royal Hospital site, and representations to the AAP Draft Plan, the

52


wording of Policy CC1 Meeting Shopping Needs and Policy CA11 All Saints have been revisited – see response to 1D: 26 under CA11 below and amended proposed wording in Appendix (separate document).

48 Our Own Future Strongly recommend moving away from allowing more branches of big corporations to open their shops and cafés as all of their profits will disappear from Wolverhampton and it will not serve the city other than a few low-paid jobs.

Planning applications are considered on their own merits and planning permissions relate to specific uses, rather than the type of businesses that providing those uses. The AAP seeks to facilitate the provision of a portfolio of different units to attract a mix of occupiers. A proportion of national multiples and anchor stores can often increase footfall and encourage linked trips which can support other types of stores.

53

Policy CC2 Offices



Proposals for 70,000 sqm office floorspace are unrealistic and will raise hope values whilst inhibiting other beneficial development. Some modern office floorspace in the right location is achievable and would be beneficial e.g. Interchange. However, the trend is for major office development to concentrate in centres such as Birmingham, and many offices in Wolverhampton and Merry Hill Waterfront are empty / under-occupied.

The AAP office floorspace proposals are supported by the Commercial Sites Assessment Study and are significantly scaled down from BCCS aspirations, but reflect a necessary level of ambition to deliver new jobs in the City. The AAP site allocations are flexible, ensuring that non-delivery of office floorspace will not unnecessarily restrict regeneration.

33 Hortons Estates Ltd There are business areas in the City that have traditionally been in and around Waterloo Road part of the City, but this is shifting towards the station with the new development there. The new office development is great to see and is the first new office development in the City for many years. This may start to define the business quarter in the City.

Noted.

Policy CC3 Leisure, Visitor and Cultural Facilities



Propose inclusion of further wording in the Policy to facilitate the objective of delivering a “safe, accessible and inclusive environment”, particularly for the evening economy where crime issues could restrict growth. This could include CCTV, parking,

Para 3.1.17 sets out the WCC approach to working with stakeholders such as the Police. The type of proposals listed are those where there are

54


hot food takeaways, ATM positioning, sheesha lounges. If the evening economy increases developer contributions may be required to police this.

recognised community safety issues and therefore WCC would consult the Police Crime Prevention officer (based part-time within the Planning office) where appropriate. There is no evidence that the AAP proposals will put particular pressure on policing infrastructure.

4 Historic England Recommend inclusion of text on the value and opportunities for heritage tourism.

Agree. Add to the end of para 3.1.13: “There are also opportunities to promote and create heritage attractions.”

5 Sport England Concern that the Policy does not address the sports needs of the new population of the AAP area. These needs can be established once the playing pitch and built facilities strategies are completed (during 2015/16) and land allocated to accommodate the need.

The AAP will provide 2,123 homes, creating a population increase of c. 4,250 by 2026. City Centre residents currently benefit from access to a wide range of sports facilities, including Central Baths pool and gym (to be refurbished), University indoor sports halls and gym, West Park tennis courts and bowling green, and Fowlers Park football pitches, and will soon be able to access a 3G artificial grass pitch, climbing wall, four court sports hall, dance studio and gym at the new Youth Zone. The area

55


south of the City Centre is served by Dixon Street Playing Fields and Phoenix Park, which were improved through All Saints and Blakenhall New Deal for Communities funding, and a new community use pitch will soon be created at St Luke’s Primary school. The outcome of the playing pitch and built facilities strategies should be known before submission of the AAP. Open space and play contributions secured from residential developments can be spent on outdoor sports provision where this is a local priority, however it is not current policy to require developers to contribute towards built sports facilities.

18 The Theatres Trust Support policy. Welcomed


Wolverhampton is lacking a major visitor attraction. Therefore an urban activity space / arena / forum with international cuisine food court should be provided as part of mixed use development on the former Netto / car parks sites (1b).

Southside (site 1b) is the best placed site in the AAP to deliver further retail-led mixed use development later in the Plan period which will complement and support the existing Shopping Core. Westside has the potential to accommodate leisure uses of the type suggested.

56


The new cinema proposed in Westside character area would undermine viability of the Lighthouse cinema.

The BCCS identifies Wolverhampton City Centre as a priority location for new cinema provision. A new cinema at Westside would serve a different market to the Lighthouse cinema and provide opportunities for linked leisure development.


Welcome the identification of a role for leisure, visitor and cultural facilities in the development of the city centre It is important that leisure uses are not developed on sites remote from or unconnected from the Shopping Core, so that linked trips and longer stay times are encouraged to enhance the visitor experience. Provision of e.g. a cinema should be seen as a logical and integrated extension to the retail shopping core, with meaningful linkages that would benefit from masterplanning

Welcomed Agreed. Policy CC3 sets out that “in-centre” locations for leisure uses are those within the ring road. The importance of connectivity between the Shopping Core (Policy CA1) and adjoining areas identified for leisure provision (Policy CA2 Westside) and important visitor and cultural destinations (Policy CA8 St Peter’s Cultural Quarter) and is highlighted by the “new/ improved linkages” symbols on the Character Area plans (and cf. Fig 6) as well as locations identified for public realm and environmental improvements.. As indicated in Policy CA2 para

57


4.3.2 more specific planning guidelines are being prepared for the Westside Character Area, that will include addressing the importance of integration and connectivity

33 Hortons Estate Ltd There are some leisure areas that need to be considered. There are some good venues such as the Grand Theatre and the Civic Halls. Those are great venues, but the experience around there is not great. There are no quality restaurants for example and the walk to the nearest car parks, especially in the case of the Grand Theatre, is not safe.

Noted

48 Our Own Future The city definitely needs a museum Policy CC3 supports the visitor and cultural economy, which could include a museum.

56 Resident Suggested additions to policy “aim”, policy text and paras 3.1.13 and 3.1.14 to include reference to the importance of the City’s religious function and churches

Whilst it is noted that religion and places of worship play an important role for Wolverhampton communities (see response and proposed amendments to paras 1.5.3 and 1.5.9 to ID 56 under ‘General’ above), reference in this policy is considered to be too specific. The city’s religious function and places of worship are covered implicitly in the reference made to ‘cultural facilities’ (and this is further emphasised in Policy CA8); para 3.1.4 cites examples of important facilities (and therefore is not specifically

58


Typographic corrections.

excluding places of worship); and the policy is also aimed at placing emphasis on commercial leisure uses. Noted

See change ref 13 in Table 3 below

Policy CC4 Providing Sufficient Employment Land


25 Blakenhall Local Neighbourhood Partnership and Action Community Forum

There appears less of a focus on local employment and training opportunities, particularly for local young people and for ‘new arrivals’ to the area. Existing employment areas around St. John’s / Ablow Street etc. – “The Warehouse Quarter” - should be retained and improved, rather than some of the area being cleared of small units and replaced with new residential units

See response to ID 25 under CA10 below.

See response to ID 25 under CA10 below.

Policy CC5 Education and Learning



The University of Wolverhampton is generally supportive of Policy CC5 and minor amendments are suggested to reflect the development proposals for the Springfield Brewery site. Suggestion to amend the second bullet point to read:

Agree with suggested changes to reflect the emerging development proposals for the Springfield Brewery site.

Change Policy CC5(ii) to state: “ii) the development of a new learning and skills campus at the Springfield

59


‘ii) the development of a new learning and skills campus at the Springfield Brewery site within the Canalside Quarter as set out in Policy CA4 to provide state of the art facilities for the needs of secondary, further and higher education sectors with industry-focussed vocational skills and training’

Brewery site within the Canalside Quarter as set out in Policy CA4 to provide state of the art facilities for the needs of the secondary, higher and further and higher education sectors and with industry-focussed vocational skills and training.”


The University of Wolverhampton is generally supportive of Policy CC5 and accompanying text. Minor amendments are suggested to Paragraph 3.1.32 to accurately reflect the development proposals for the Springfield Brewery site: “The Springfield Brewery site has been identified as a key development opportunity to provide secondary, further and higher education facilities together with industry-focussed vocational skills training. The site has excellent public transport access via the Interchange. The Springfield Brewery site will be developed out in accordance with the Springfield Campus Strategic Development Framework.”

Agree to make changes to reflect the emerging development proposals for the Springfield Brewery site.

Change para 3.1.32 to state: “The Springfield Brewery site has been identified as a key opportunity to provide secondary, further and higher education facilities together with industry-focussed vocational skills training. The site has excellent public transport access via the Interchange. It is proposed to develop the Springfield Brewery site in accordance with the Springfield Campus Strategic Development Framework. a combined higher and further education and training

60


centre with excellent public transport access via the Interchange.” Add to end of Table CA4A, Site 4c, Further Information text: “… A planning application has been submitted for part of the site (5,400 sqm) and it is anticipated that the remainder will be developed in accordance with the Springfield Campus Strategic Development Framework.”


The University of Wolverhampton is generally supportive of Policy CC5 and accompanying text. Minor amendments are suggested to paragraph 3.1.34 to emphasise the wider benefits of investment in learning facilities

This paragraph relates to the sustainability appraisal findings, which will not be included in the Publication Plan.


Support bringing redundant Springfield Brewery site back into beneficial use after destruction of much of the site by a fire in 2006.

Welcomed

Policy CC6 Transport



General support for the Policy. Request wording is included in the Policy and

Welcomed The police are consulted on

61


justification to ensure the police are consulted on transport proposals and large-scale developments, to enable full consideration of security and safety issues. Request wording is included in the policy to promote provision of safe storage of cycles as part of development. Request wording in Policy (and Policy CA3 bullet point (e)) encouraging car park “Park Mark” accreditation.

proposals where appropriate in line with existing UDP / BCCS policies. Cycle storage is covered elsewhere in BCCS Policy TRAN4 Creating Coherent Networks for Cycling and Walking It is not within the remit of the AAP to set such standards, which cover issues which cannot be controlled through planning. The police are consulted on car park proposals where appropriate.

3 Natural England Support requirement to improve pedestrian and cycling links, including through maximising use of the canal network, which has the potential to provide benefits for people and wildlife.

Welcomed

4 Historic England Transport proposals should be assessed for their impact on the historic environment, and opportunities for enhancement to the historic environment considered.

Impact on the historic environment is one of the key factors taken into account when formulating transport proposals.

6 Canal and River Trust

Welcome the references to the canal network in the policy and supporting text. Wish to be involved in detail of three proposals affecting the canal, particularly the proposed bridge in the Canalside Quarter.

Welcomed Agree. The bridge proposal has been deleted (see Table 3).

8 Highways England (Highways

Welcome aspiration to create a sustainable City Centre and measures under Policy CC6 to improve

Noted

62


Agency) accessibility and provide more effective and efficient transport systems.


Car park charges for evenings and Sundays will be counter-productive as far as night-time economy / Sunday shopping are concerned.

Noted. Parking charges are not within the remit of the AAP.

22 Wolverhampton Cycle Forum

Aware that WCC is in the process of preparing an Active Travel Strategy, which is expected to take a year to complete and will audit current cycling infrastructure across Wolverhampton and make recommendations on opportunities to improve infrastructure and increase participation. The AAP should use the strategy outputs to inform cycling proposals in the final AAP. Therefore some flexibility should be retained to adopt the Active Travel Strategy when it becomes available.

The AAP sets out a general direction of travel for the area and is flexible to respond to changing evidence and needs. The Active Travel Strategy will cover detailed

matters, including highway works, which are unlikely to be constrained by the more general planning proposals and policies set out in the AAP.

23 Wolverhampton on Wheels

There should be an influential person appointed within WCC as a focal point throughout the design and development period of Policy CC6 (b) Walking and Cycling. A lack of this focus in the past has resulted in very patchy and stop-go provision. This role should initiate a scrutiny panel including officers, Elected Members and members of the public, to oversee progress and tackle problems at an early stage, to save money and prevent longer term problems. A coherent, safe, convenient cycle infrastructure has benefits for everyone, not just cyclists, and must be given a high priority, because: i) Public health is improved through better air quality / benefits of exercise ii) Economic growth is enabled by facilitating mobility

WCC Transport team provide a focus for delivery of cycling proposals in the City, including the city centre.

The AAP acknowledges that cycle infrastructure and a successful transport network is essential to achieving economic prosperity and sustainable communities.

63


and access to work & training for socially disadvantaged groups; congestion is reduced; investment increases as Wolverhampton becomes a more attractive place to live and work. iii) Contribution to sustainability targets by reducing CO2 emissions. Need to acknowledge who the cycle infrastructure is being designed for to make it an attractive alternative to car use. It must be designed for people of all ages and confidence levels and need to consider the likely users in 20 years’ time e.g. people who grew up regarding cycling on the road as dangerous /travelled to school by car/ see pavements as the safe option /generally less active/fit. Need to follow Best Practice in other cities e.g. Seville, Utrecht. Part of the answer is to replace “it can't be done” with a “can do” attitude. Actively involving people who regularly use bicycles for transport will also prevent design errors.

Noted. The AAP sets the framework for improvements and identifies the areas for improvement. The detailed design proposals will be developed as schemes come forward.

31 & 56

St Peter’s Collegiate Church & Resident

Add to end of Policy CC6 (d) (iii) “including retention of those surface car parks which are vital to different City Centre users, such as St Peter’s, Broad Street and Fold Street car parks, where demand and income dictates, and the need of existing users such as places of worship must be respected, and the Council’s long standing agreements need to be honoured such as the Collegiate Church of St Peter with the St Peter’s car park.” Suggest para 3.1.43 should read “In order to achieve the development outputs identified in the AAP the development of other public car parks may be considered. Developing some surface level car

Agree that the Draft Plan Policy could clarify the Policy towards existing car parks which provide an important role in supporting the City Centre. Agree that the Plan would benefit from clarification on the approach to the phasing of development of existing car

Additional numeral (iv) to Part (d) of Policy CC6 to state: “iv. The retention and possible enhancement of existing car parks which are important in supporting the functioning of the City Centre” Amend Para 3.1.47 to state: “….A phased approach will be taken to the release

64


parks may contribute towards jobs, homes and diversify the retail and leisure offer in the City Centre and enhance the built environment, so long as the loss of parking does not negate these possible gains.” Para 3.1.47: add to end of first sentence: “subject to these proving profitable to develop” Para 3.1.49 second sentence replace “discourage” with “help to reduce” and add to end of second sentence ”, but there are many reasons why the use of private cars can be essential, and to discourage their use may have a negative effect in turning people away from the City Centre.”

parks. This is best explained in paragraph 3.1.47 The suggested wording is implicit in the existing wording Sustainability appraisal sections will not be included in the Publication AAP (see Table 3 below).

of car parks in order to achieve no overall net loss of parking spaces by 2026, and in order that the effects of the closure of individual car parks can be monitored to inform the decision and subsequent delivery of development and replacement car parking spaces where necessary”.

39 Resident Urgent need to re-route the metro to include Market Street and Lichfield Street to give direct access into the town. It is not satisfactory to expect people to walk to the town centre from the bus station, especially disabled users. Buses pass through the town centre for passengers benefit so should the Metro. This may have the benefit of bringing more people into the town. Having been partially disabled for a period of time I am well aware of how important it is that public transport will deliver me close to the location I need.

There are logistical issues regarding the routing of the metro which do not affect buses. It is not possible to bring the metro further into the city centre, however it is possible to extend the metro to create a public transport interchange, maximising opportunities for all users to make best use of the excellent public transport links

65


Public car parking should in general be free. There are commercial providers who charge for the convenience they provide, but charged car parks do not encourage people into the town centre. Access to the town centre is not easy as pedestrianisation is needed but there is a need to encourage people into the town centre. The loss of income to WCC would be offset by the potential increase in rates and spending brought about by increased footfall. A vital town centre also brings investment in shops, makes the town more desirable and thereby encourages businesses to locate/relocate to Wolverhampton providing much needed jobs and consequent spending.

available from Wolverhampton. Noted. Parking charges are not within the remit of the AAP.

48 Our Own Future Suggest that for car parking were that multi-storey car parks are the way to go to overcome the land space issue

Agreed. Multi-storey provision is supported at the Interchange and Westside Character Areas.

54 Resident Long term transport proposals for the city centre: 1. Protect railway trackbed between Bushbury

railway junction and Cannock Road railway junction leading to Low Level station.

2. Promote low level station for HS2 station 3. Extend the tramline into low level station via the

disused railway tunnel that would link Birmingham Snow Hill and Dudley railway stations

These proposals fall outside the remit of the AAP.

56

Resident

Typographic suggestions to Policy CC6 (b) & (d) and

paras 3.1.44, 3.1.46 and 3.1.49

Noted See change ref 13 in

Table 3 below.

66

Policy CC7 Delivering a Sustainable Mix of Housing


4 Historic England Housing proposals should be assessed for impact on the historic environment – the evidence should reflect this.

The details provided for each development opportunity in the tables in Part C should reflect an evaluation of any historic environment constraints and opportunities, including the potential effects on views of landmark buildings and the proposed designation of historic landscape characterisation sites. Further work has been undertaken regarding undesignated archaeology for development opportunities, which will be reflected in changes to Part C.

Various changes to Part C (see below)


Welcome references to the canal network in supporting text. Canals are attractive settings for development and are being used for place-making.

Noted.


City centre living to revitalise and increase spending, security and ownership of the City Centre has been a goal in Wolverhampton for 20 years. WCC and partners should have capitalised on this, but little has been achieved. The AAP housing target should be higher, as the original target within the Ring Road was 3,000 homes

The recession severely hit the housing market and particularly delivery of high density city centre housing. The AAP housing target is realistic given current market conditions and represents a minimum, with identified potential to deliver a further 840 homes at least. Office floorspace proposals reflect a necessary level of ambition to deliver new jobs in

67


the City. The AAP site allocations are flexible, ensuring that non-delivery of office floorspace will not unnecessarily restrict regeneration, including potential housing development.

48 Our Own Future In terms of housing in the city centre, it's very important to make use of existing buildings first. Students would gladly take up those as long as they are cheap enough and there needs to be a homeless shelter established in one or more buildings. As homelessness is very small here, we should aim to eliminate it and make that achievement public. Having more people living in the centre would make it feel safer with fewer desolate areas and this should lead to more businesses opening as the centre becomes more vibrant.

Agreed. The AAP supports increasing the residential population by reusing existing buildings (particularly the use of upper floors), and the provision of student accommodation.

Policy CC8 High Quality Design and Public Realm



General support for the Policy. Request additional wording in Policy (and cross-referenced in Character Area policies) to ensure Secured By Design standards are met. Request additional wording in Policy to ensure the public realm is appropriately maintained, to avoid

Noted BCCS Policy ENV3 ensures that all developments proposals in Wolverhampton include “consideration of crime prevention measures and Secured By Design principles”. Agree.

Amend Policy CC8 to

68


neglect. state: “(vii) Protect the settings of and views to heritage assets to help promote local distinctiveness; (viii) Promote sustainable maintenance and management of the public realm”

4 Historic England Support the Policy, including references to historic environment and Townscape Heritage Scheme. Recommend include “significance” in vii It would be beneficial to plot other historic environment designations on figure 8.

Noted Agree Agree the figure 8 should show the full range of historic environment designations in the City Centre AAP area.

Amend vii) to “protect the significance of setings of and views to heritage assets…” Add Historic Parks & Gardens (West Park) and Scheduled Ancient Monuments (St Peter’s Church) to figure 8 and figures in Part C.


Welcome references to the canal network in supporting text and the opportunity to work with WCC to identify priorities.

Welcomed


Welcome recognition in AAP that convenient, safe and inviting pedestrian links will improve the function, vitality and viability of the City Centre. However, there are no satisfactory crossings over the Ring Road, St Peter’s underpass is unchanged and the Sainsbury’s development has not delivered a pedestrian boulevard to Market Square. Lessons could be learnt

Noted. Crossings over the ring road have been improved in recent years and there are further proposals to increase accessibility in the AAP.

69


from Birmingham.

33 Hortons Estate Ltd The public realm is one area where improvement is needed. Also de-cluttering of streets, which includes the reduction in the number of street trading activities. A safer and cleaner environment is needed. One of my main concerns is to ensure that there is permeability through the City centre. We have made comments on the application with regard to the Mander Centre for example that is closing some of the routes through. Linkages through to Victoria Street, for example need to be improved and enhanced.

Noted

46 Resident Need for updated and improved signage - the ring road signs point to theatre instead of theatres (Grand and Arena) and to the museum and art gallery (not a museum for more than a decade).

Noted. Para 3.3.6 notes that a Public Realm Design Guide is being prepared by the Council, which will cover signage.

Para 3.3.6 after ”pedestrians,” add “improving signage and wayfinding”

48 Our Own Future (E Lord)

Multi-storey car parks could include a city park. It is important for people to have somewhere green to go in a city centre, on their lunch breaks, for example, plus it would stand out as being innovative to have a high-rise park.

Policy CC8 supports enhanced public realm (and Policy CC10 includes support for the provision for Green Roofs). ‘High-rise’ park potential could be explored in the Public Realm Design Guide (para 3.3.6) which the Council is preparing

70

Policy CC9 Protecting and Enhancing Historic Character and Local Distinctiveness



Request additional wording in Policy to give favourable consideration to use of alternative materials to replace stolen building materials/artefacts e.g. lead in appropriate circumstances, as part of a pragmatic, flexible approach.

Existing BCCS / UDP policy allows for a flexible approach, considering the use of alternative materials for each site on its merits.

4 Historic England Support the Policy, including references to the BCCS and evidence. Recommend including clause to protect, conserve and enhance heritage assets. Mitigation should require recording by a professional and updating the Historic Environment Record. Buildings of under 20m in height could affect the setting / views of heritage assets and local landmarks.

Noted. Consider this is covered sufficiently in BCCS ENV2 and the UDP saved policies HE1-28. Agree. The Policy attempts to strike a balance between protecting views and requiring all developers to assess potential visibility affects. Buildings of over 20m are highly likely to cause harm to visibility and therefore an assessment is always required, as set out in (c). However, (d) and para

Add to end of para 3.3.18: “… Where there is no alternative to loss, recording must be carried out by a qualified professional and the Historic Environment Record updated.”

71


Undesignated archaeology should be covered in the Policy.

3.3.22 also ensure that developments of less than 20m which could potentially have an effect are also required to carry out an assessment to clarify any impact. Consider this is covered sufficiently in UDP saved policies HE24-28.


Welcome references to the canal network in supporting text. Canals are attractive settings for development and are being used as vehicles in place making

Welcomed


Support Policy CC9 approach to ensure conservation of significant of the historic environment, including designated and non-designated heritage assets, and providing opportunities to enhance assets at risk. Understanding context and appraising character is key to informed decision-making, so support use of comprehensive studies such as the Historic Landscape Characterisation and Viewsheds study and principle to conserve and enhance heritage assets through sensitive development and environmental improvement. There is a strong indication of local character and distinctive features and how key heritage assets can contribute toward regeneration.

Welcomed


The WCC historic environment team is now too small to implement the AAP, including proactively bringing derelict / at risk heritage buildings back into use.

Recent budget cuts have had an impact on some WCC services. However this should not affect the priority accorded to the historic environment in the AAP.

56 Resident Typographic suggestions to para’s 3.3.12, 3.3.13 and Noted See change ref 13 in

72


3.3.15 Add to end of para 3.3.13: “Also within the City centre and linked to the City’s wool and cloth trade history are a number of Folds, some in good economic use, some in poor repair, and their historic links could form the basis for a comprehensive look at making them a focus of interest to encourage restoration of buildings and bringing them into economic use.” Also add reference to end of para 3.3.15 to www.wolverhamptonfolds.co.uk with information on the wool trade / folds and improvement recommendations.

Agree that the Folds are a distinctive feature of the historic environment in the City Centre which merit including in the list of heritage assets.

Table 3 below Amend para 3.3.12 to state: “… Heritage assets range from churches and civic architecture to canal locks, folds (alleys, passages and little streets linked to the wool and cloth trade), a railway station…”

Policy CC10 Delivering Environmental Infrastructure in the City Centre


3 Natural England General support for the Policy, including the Green Roof and SUDS requirements, particularly regarding wildlife habitat connectivity. The justification should clarify that both existing and new assets are relevant to the Policy, and reference should be made to Natural England’s standards for accessible natural greenspace.

Welcomed BCCS Policy CSP3 and para 3.3.25 explain in sufficient detail the nature and type of assets which are the subject of Policy. Wolverhampton has local open space standards, set out in the recently adopted Open Space, Sport and Recreation SPD.

4 Historic England The role of the historic environment in environmental infrastructure should be recognised and how

The role of the historic environment and how proposed

Amend justification and relevant text in Part C (see

http://www.wolverhamptonfolds.co.uk/

73


environmental improvements potentially impact on the historic environment e.g. in the Canalside Quarter, should be explained.

environmental improvements will protect, conserve and enhance the historic environment could be better reflected in the justification and Part C.

below).


Note references to the canal network in the supporting text and recommend guiding principles for waterside development.

The guiding principles referred to in the consultation response are sufficiently covered in BCCS Policy ENV4 Canals and Policy CA4 Canalside Quarter - the only part of the City Centre AAP area which includes canal.


The Green Roofs requirement requires further justification than the single sentence “Green roofs on new developments could play a role in supporting existing ecological networks” given their expense of both capital costs and maintenance. The inclusion of a green roof should be a “consideration” for the determination of development rather than a “requirement” so that this does not restrict proposals coming forward.

1. A number of BCCS policies support the proposed policy requirement for green roofs, as demonstrated by the recent adoption of an identical requirement in the Bilston Corridor and Stafford Road Corridor AAPs (2014), which was supported by the Stafford Road Corridor AAP Inspector in his report (see detail for further supporting information).

2. BCCS Policy CSP3 requires development to demonstrate that the strategic network of environmental infrastructure will be protected, enhanced and expanded, to be achieved through implementation of the

74


EIG Phase 2. The EIG maps the “Environmental Infrastructure Benefit Priority Areas”, including the City Centre, “… where environmental infrastructure interventions and initiatives should be prioritised”. Policy ENV3 requires development to deliver high quality design by: “6. Including design features to reduce the urban heat island effect such as…green roofs and the inclusion of green space in development”. Policy ENV5 expects all development to help reduce flooding and potential urban heat island effects by meeting 5 criteria, including: “e) Create new green space, increase tree cover and/or provide green roofs”. Policy ENV6 identifies the role of open space to include improving the image and environmental quality of the area and reducing potential urban heat island effects. The City Centre is densely developed with limited areas of green space, and developments have limited potential to provide new open space. Therefore it is particularly important to take

75


opportunities to provide green roofs, to contribute to sustainable drainage, create habitat for wildlife and reduce the urban heat island effect. The green roof requirement in Policy CC10 only applies to larger developments and will not restrict development coming forward as there is allowance for the requirement to be waived if it is not viable or feasible.


Policy CC10(b) requires the provision of Green Roofs as part of all new development of 1,000sq metres or more including education facilities. It will be very difficult for institutions to maintain green roofs in the long term and presents greater pressure on engineering services. Please consider the omission of this provision in respect of education developments.

See response above to respondent ID34.

Policy CC11 City Centre Renewable and Low Carbon Energy Infrastructure


3 Natural England Support the policy. Welcomed

4 Historic England Recommend measures to ensure making use of canals for renewable energy does not harm the historic environment.

Para 3.3.44 refers to this, and there is more detail in the adopted Renewable and Low Carbon Energy SPD.


Welcome recognition of opportunities canals can provide for heating and cooling of buildings.

Welcomed

76



While the policy criteria do not make specific mandatory requirements on development on-site low and zero carbon energy, including heat networks, are very dependent on the nature and scale of the development in question. In some instances the use of any of the technologies referred to by the policy will be unfeasible or inappropriate. The policy should be reworded to recognise this and remove the obligations to address this policy for development under 1,000sqm. The policy should acknowledge the substantial contribution that will be made to the construction of low carbon buildings through compliance with the Building Regulations which currently require substantial reductions in carbon emissions that will ultimately result in Zero Carbon development from

3. A number of BCCS policies support the proposed policy, as demonstrated by the recent adoption of an identical requirement in the Bilston Corridor and Stafford Road Corridor AAPs (2014), which was supported by the Stafford Road Corridor AAP Inspector in his report (see detail for further supporting information). The policy requires the potential for renewable technologies to be explored as part of the hierarchical approach, therefore if they are proved to be unfeasible (and a fabric first solution is not possible) allowable solutions are the “fall back” position.

The policy requirement cannot be limited to developments of over 1,000 sqm as any size cut-off criteria will depend on future changes to building regulations.

The policy aims to address the implications of changing building regulations requirements for planning.

77


2016 and 2019.


The policy refers to the BCCS which predates the NPPF and recent Government reforms. Para 3.3.40 refers to BCCs Policy ENV7. This should be updated with reference to Building Regulation Updates (2013), which acknowledges the energy saving principles of applying a building fabric led approach (Fabric Energy Efficiency – FEEs) and how this can be classified as a low carbon approach, rather than relying on ‘bolt-on’ renewables which over the lifetime of a building incur maintenance costs and a reduction in efficiency. A fabric first approach ensures the energy saving principles of a building is inherent in the design and therefore requires no maintenance, delivering the energy reduction savings over the lifetime of the building.

The BCCS is compliant with the NPPF and Policy ENV7 is consistent with recent Government policy reforms, including those relating to housing standards. The proposed policy does advocate a fabric first approach (a), in preference to a renewables approach (b).

48 Our Own Future Multi-storey car parks could have solar panels.

Policy CC11 supports the provision of renewable energy generation, such as solar panels

Policy CA1 Shopping Core


4 Historic England Need detail on how listed and locally listed buildings and conservation areas will be considered and any impacts mitigated / enhancement opportunities developed.

Agree that this should be addressed - see response in General table above.

Amend Policy CA1: “… New development will be supported where this complements and broadens the current offer and preserves or enhances the character or appearance of the

78


Recommend consideration of shop frontage and signage design in the conservation area, or link to BCCS if covered there.

UDP policies cover requirements for development within conservation areas.

Wolverhampton City Centre and Worcester Street conservation areas.” Add to end of para 4.2.2: “… , whilst respecting the historic character and local distinctiveness of the conservation areas covering much of the area.” Table CA1A Further Information for site 1b(i), add to end: “…in keeping with the conservation area covering part of the site.”


Support the Vision and Phasing set out in Policy CA1 Welcomed


Support the identification of an area for enhancement and refurbishment within the shopping core as it encourages regeneration and revitalisation of the core and will meet a key objective of the AAP to deliver a more prosperous City Centre. Policy CA1(e) contradicts current permitted development rights which allow the change of use from A1 to A2 or A3. Whilst this is a temporary change, there are currently proposals to make this permanent. This part of the policy should be kept

Welcomed As the AAP will run to 2026 and NPPF para 23 states that local plans should define ’primary and secondary frontages in designated centres, and set

Policy CA1(e) after “frontage,” add “proposals for“, and after “a change of use that” add “are subject to planning control and”

79


under review to ensure that the policy is deliverable. policies that make clear which uses will be permitted in such locations’ it is felt important to include a frontage policy in Policy CA1(e). The Town and Country Planning (General Permitted Development) (England) Order 2015 came into force on 15 April 2015, which makes change of use from A1 to A2 permitted development and requires ‘prior approval’ for change of use from A1 to A3, within a certain floorspace threshold – subject to consideration of a range of environmental impacts and policy considerations. The proposed adjustments to the wording of CA1(e) take this into account. This part of the policy will be kept under review to take account of any future permanent changes in permitted development rights.

37 Planware Ltd Policy CA1 should be deleted – the Framework provides no justification at all for using the development control system to seek to influence the location of A3/A5 uses, nor is there any evidence to justify the underlying assumption of the Policy that locating A3/A5 uses within certain areas causes adverse consequences which would in turn have

Disagree. The Policy is consistent with para 23 of the NPPF which states that local plans should define ‘primary and secondary frontages in designated centres, and set policies that make clear which

80


negative land use planning consequences. uses will be permitted in such locations’. The glossary to the NPPF refers to primary frontages containing a high proportion of retail uses. In secondary frontages there is greater opportunity for other uses such as restaurants (Use class A3).

46 Resident Anchoring the retail offer around a renovated Mander and Wulfrun Centre may improve footfall and retail takeup during the day but will make the city centre unwelcome during the evening when locked and shuttered. Reinstating some of the old street lines and having multi-use buildings (Japanese-style) might tackle this.

The Retail Update Study advises that the initial focus should be on refurbishment of the Mander Centre.

56

Resident

For Table CA1A, Southside 1 and Southside 2 amend Further Information entries to read: “Mixed use retail and other development, to include residential accommodation above shops where practical, and to include retention and refurbishment of all properties in Victoria Street and Worcester Street, in Worcester Street Conservation Area.”

It would not be effective to include this wording. The potential of upper floors for residential use is already supported e.g. in Policy CC7. Southside 2, Site 1b(ii), is not identified for residential provision. It may not be possible to retain and refurbish all properties in the Conservation Area within Southside 1. Some properties have had to be demolished due to their dangerous structural condition. However, any new scheme would be required to preserve or enhance the character or

81


For Southside 3, add to end of “Further information” entry: “to include retention of built retail frontage to Cleveland Street, and refurbishment and economic use of vacant 1830’s Cleveland Street building.”

appearance of the Conservation Area. The building in question (20-21 Cleveland St) has now been demolished. It would not be effective to include the additional wording as such a requirement might constrain future regeneration. Any future planning applications would be considered in terms of relevant planning policies, including those relating to the historic environment and design..

Policy CA2 Westside


4 Historic England Welcome para 4.3.3 and recognition of historic characteristics of the area. Need detail on how listed and locally listed buildings will be considered and any impacts mitigated / enhancement opportunities developed.

Noted. Agree that this should be addressed - see response in General table above.

Table CA2A Further Information for sites 2a(i) and 2a(iii), add to end: “…in keeping with the conservation area covering part of the site.”


Fig 14 shows different development opportunity boundaries to Figure 11

Noted. Fig 14 is a three-dimensional representation of the City Centre, indicating the

82


Table CA2A - Policy CA2 references high quality redevelopment to the frontages of Ring Road St Marks, School Street and Worcester Street. However, reference to School Street is absent from ‘Table CA2A: Development Opportunities’ ‘Further Information’ column Para 4.3.6 - reference should also be made to ancillary leisure, food and drink uses which are also complementary to a cinema provision

location of development opportunities, where surface levels are highlighted in red. This means that built-structures obscure the red highlighted areas. These images are not used for site-specific policy purposes - Fig 11 and detailed Character Area figures such as Fig 15 provides the definitive site-specific boundaries and proposals Agreed. Agreed.

Table CA2A, Westside 3, Further Information add “School Street” Para 4.3.6 second sentence after “ancillary retail” add “leisure, food and drink” Table CA2A Appropriate Uses for Westside 1 - 3 after “ancillary retail” add “, leisure, food and drink”


Support the importance of linkages to the Shopping Core in para 4.3.2 Add the significance of these links to the Vision and

Welcomed Agreed. The importance of

Add to the end of the

83


criterion C of Policy CA2 linkages also includes across the ring road to the Sainsbury’s Store in the Chapel Ash & West Park Character Area.

Vision “with excellent linkages to adjoining areas” Add to the end of Policy CA2 (c) “and enhance linkages to adjoining areas” Amend Figure 5 T4 to state: “Explore opportunities for enhanced pedestrian and cycling crossing point including improved access within of the ring road and beyond to the shopping core”

56

Resident

For Table CA2A, Westside 1, add to end of “Further information” entry: “, to include for continued refurbishment and bringing back into economic use historic buildings fronting Pitt Street and Worcester Street.” For Westside 3, add to end of “Further information” entry: “, to include for retention of major well-used public car park (Fold Street), refurbishment of Methodist Church buildings, and refurbishment and bringing back into economic use of vacant historic locally-listed building fronting School Street.”

It would not be effective to include this wording. The buildings fronting Pitt Street and Worcester Street do not fall within Westside 1, Site 2a(i) It would not be effective to include this wording. The AAP seeks to ensure no net loss of parking spaces across the AAP area. Some car parks are identified as development opportunities that could come forward for development over the length of the plan period in order to achieve the aims of the

84


AAP. A Car Parking Strategy for the City Centre is being undertaken. Westside 3 could not realistically deliver refurbishment of the Methodist Church and re-use of the locally listed 7 School Street, as both lie outside the development opportunity site boundary.

Policy CA3 City Interchange and Commercial Gateway


4 Historic England Amend wording to reference need to protect, conserve and enhance heritage assets and their setting, and how listed / locally listed buildings will be safeguarded.

The policy sets out a key priority, which is to focus on enhancing the setting of important heritage assets. Agree that this should be reflected in changes to Table CA3A - see response in General table above.

Table CA3A Further Information: for site 3a, amend to: “…Exemplary standard of design to reflect gateway location, create new civic spaces, maximise canalside location and enhance the conservation areas covering parts of the site and the setting of the Old Steam Mill Grade II listed building..”; for site 3b, add to end: “…in keeping with the conservation area

85


covering parts of the site.”


Welcome references to the canal network in policy and supporting text. Planning obligations from waterside development should be invested in waterways infrastructure. Waterside development should be appropriately designed.

Noted. Appropriate design of waterside developments and securing planning obligations for waterways infrastructure are sufficiently covered in BCCS Policy ENV5 and AAP Policy CC12.


The policy shows commitment by the Council to enhance the setting of important heritage assets including the Old Steam Mill

Welcomed

32 Harris Lamb Ltd The former Post Office site (site 3e) should be allocated for housing-led mixed use development of up to 250 residential units with potential ancillary commercial development. The site is brownfield and in a highly sustainable location and would help meet the City’s housing needs. Residential use would support local businesses and is an accepted town centre use. The principle of housing development has been approved by the Council previously.

WCC has previously granted permission for housing schemes on site 3e (2002, 2007). However, these schemes were not implemented and the site has been in use as a temporary car park for 4 years. The BCCS and the AAP provide the opportunity to revisit the longer term potential of the site in the context of the pivotal Interchange project. Site 3e is the largest development opportunity site in the Interchange area with significant potential to deliver Grade A office space. Therefore it is important that the site is protected for office use.

33 Hortons Estate Ltd The railway station should be finished off, together with Metro to improve linkages.

Noted.

86

Policy CA4 Canalside Quarter


4 Historic England This is an important area for heritage and the policy should contain a positive strategy. Request amend wording to reference need to protect, conserve and enhance heritage assets and their setting in line with the NPPF and how listed buildings will be converted including assessment detail, design and mitigation measures.

It is considered that the importance of the area for heritage and the treatment of listed buildings is generally covered in sufficient detail, however references to conservation areas could be improved.

Table CA4A, add to end of Further Information: For site 4d: “..and in keeping with the conservation area covering part of the site” For site 4j: “… Development should be in keeping with the conservation area within which the site falls.” For site 4k: “… , be in keeping with the conservation area within which the site falls and address the canal..” For site 4l: “… Development should be in keeping with the conservation area within which the site falls and address the canal.” For site 4n: “… Development should be in keeping with the conservation area within which the site falls and address the canal.” For site 4m: “… Development should be in keeping with the

87


conservation area covering part of the site and address the canal.”


Welcome requirements in the policy which reflect CRT design guidelines and the aim to increase supply of residential moorings, regarding which consultation on specific proposals is welcomed. Request that support for restoration of wharfs and basins should be only where appropriate.

Noted. The CRT will be consulted on any specific proposals for residential moorings. Agree.

Amend policy wording: “… Proposals affecting the canal corridor should: … Protect and exploit, through appropriate landscape design or restoration to active use, the remains of former wharfs and infilled basins where appropriate.”


The University of Wolverhampton is generally supportive of Policy CA4 and accompanying text. The University of Wolverhampton has endorsed a vision to secure transformational change of the Springfield Brewery site and create a campus environment.

Welcomed

27 Turley Add bullet (f) to Policy CA4 to say “Development of a medium-sized foodstore to serve the existing and proposed residential population on a site on Broad-Gauge Way (4i) Amend development outputs to include 1,800sqm food store. Amend Table CA4A for Site 4(i) to include retail (A1) under “Appropriate Uses” and “or 1,800sqm

Noted. Site (4i) is already mentioned in Policy CA4(d). The first paragraph of Policy CA4 mentions supporting complementary retail uses in this character area. The need for complementary retail provision in the Canalside Quarter is recognised in Policy

Table CA4A Site 4(i) “Appropriate Uses“ add “/ a convenience store to

88


retail” under Development Capacity CA4. The HV Retail Update Study (para 7.30 (x)) and Addendum Letter notes that convenience need could be met through provision of a number of smaller stores to serve the city. Therefore, the potential for this site to provide a small convenience store is recognised and consistent with proposed Policy CC1 (f). The precise form and quantum of retail provision would need to be established in principle on the site through a planning application. Table CA4A indicates the total development capacity for Site 4(i)

serve the existing and proposed residential population of the local area”


Important to ensure there is no scope for the broadening of the restricted retail uses permitted so as to prejudice investment in the shopping core In the Vision add “uses complementary to the shopping core” after “retail” Policy CA4(a) add “uses complementary to the shopping core” after “retail”

Noted. In addition to any existing retail sites, future retail provision in the Canalside Quarter should seek to serve the new residential areas being planned for in this Character Area and existing surrounding residential communities, thus complementing the function of the Shopping Core. Policy CC1(e) would ensure that

89


complementary retail uses come forward that do not prejudice the functioning and priorities of the Shopping Core.


Support specific mention of introducing retail uses to the Canalside Quarter as it recognises the role that such development plays in creating vital and vibrant communities. Welcome identification of the Peel Centre in Fig 19 which illustrates the Canalside Quarter assets and opportunities The policy lists the redevelopment and refurbishment of sites off Stafford Street, including the Peel Centre as key priorities. The identification of development at the Peel Centre and other land to the north as a priority is welcomed Support development outputs listed in para 4.5.7 and within Table CA4A quoting the floorspace figures for either of the recent consents at the Peel Centre. This should be replicated in Policy CC1 As the Peel Centre is a priority location, and the nature of this part of the Character Area along a major arterial route into the City Centre would like the designation of the site supported by a wider range of land uses at the adjacent Site 4(f). The inclusion of additional retail floorspace and a hotel and car showroom would help create a critical mass and appeal to a wider range of occupiers/ developers, improving the chance of redevelopment/ regeneration

Welcomed Welcomed Welcomed Welcomed. See comments to ID: 36 Policy CC1 above Policy CA4 mentions supporting a complementary mix of uses, and this is emphasised for Site 4(f) as it is identified in Policy CA4(a). Table CA4A includes reference to a number of different uses, including leisure (which could include a hotel, subject to Policy CC3). Future

90


and would help ‘soften’ the transition between the Peel Centre and proposed residential properties which would benefit their general amenity

proposals would be assessed on their own merits. Due to site constraints a car showroom might not deliver sufficiently high quality development in this key gateway location. Some ancillary retail might be appropriate to serve on-site uses, such as office or residential, subject to Policy CC1, see para 3.1.7

35 West Midlands Metropolitan Area Canals Partnership

The canal at the top of the 21 locks is not inviting for an overnight stay. The moorings are so secure that boaters have no access to the City, so the City is likely to miss shopping/economic activity, with boats making instead for Birmingham or Merry Hill. The City needs to generate or encourage overnight, secure, accessible moorings close to Broad Street.

Policy CA4 requires developments affecting the canal corridor to increase the supply of residential moorings within suitably located and well-managed sites. There is a long term aim to create secure and accessible overnight moorings at Broad Street Basin.

48 Our Own Future Suggest that the Gateway area in Horseley Fields is considered for use as a park which was a winning entry in the Forgotten Spaces competition for ‘Everybody Park’, a multi-sensory park made from recycled materials.

Policy CA4 supports the provision of open space to serve local residential communities.

91

Policy CA5 Chapel Ash and West Park


4 Historic England Regarding the opportunity for development at locally listed Former Eye Infirmary (Site 5a), has the potential impact and how the building will be protected and conserved been assessed? Encourage inclusion of text in the policy / justification section to detail the approach, in line with requirement on page 94 for sensitive restoration.

It has been assessed that there is potential for sensitive re-use of the locally listed buildings and redevelopment of other parts of the site, as set out in the further information section. No further detail is required.

9 Royal Wolverhampton NHS Trust

The buildings on the former Eye Infirmary site (Site 5a) do not meet the requirements of being classified as a landmark building as set out in Policy CC9. The buildings have been extensively modified and the Trust considers they have little architectural merit and do not have a “distinct character or create a sense of place”. The former Eye Infirmary should be identified for re-development for retail use. “Housing- led” mixed use is not appropriate for this site and the existing buildings are not suitable or appropriate for re-use.

Buildings on the Former Eye Hospital Infirmary site are locally listed. The status of landmark building does not provide any additional policy protection, rather this designation affects other sites where development may affect views of the Former Eye Infirmary. Residential is the use most likely to support conversion of the existing locally listed buildings on site 5a. The Commercial Sites Assessment Study states that the site has potential for a residential scheme with ground floor retail and should be identified for residential-led mixed use development, subject to extensive refurbishment and possibly selective demolition.


Pleased that mixed use development opportunities at the local listed former Eye

Welcomed

92


Hospital (which is severely at risk) is a key priority.

55 Resident Support Policy CA5 Welcomed

Policy CA6 University Quarter



General support for references to enhancements to pedestrian legibility and creating a safe and accessible environment.

Welcomed

4 Historic England Policy should contain reference to heritage assets and the need to protect and conserve them and identify enhancement opportunities where possible, and text regarding need for height and design of development to respect the views and setting of heritage assets mentioned. There are a number of listed buildings/locally listed buildings within the quarter, but no specific reference to these and how they will be protected, conserved and where possible enhanced through development. Support retention and conversion of the listed Hatherton Arms.

The only designated heritage asset which will be affected by a proposal for this Character Area is the Hatherton Arms, which is referenced in Table CA6A (support welcomed). Height and design issues are also covered in para 4.7.5. Therefore no further references are required.


Please delete the reference to ‘green roof top gardens’ in para 4.7.2

See response to Policy CC10 respondent (13).


The University of Wolverhampton is generally supportive of Policy CA6 and accompanying text. Minor amendments are suggested to paragraph 4.7.1 to reflect the latest programme for completion of the Business School.

Welcomed. Agree para 4.7.1 needs to be updated to reflect progress.

Change last sentence of para 4.7.1 to state: ‘…..Recent developments at the City Campus include a new science facility and a Business School.”

93



A prime opportunity of this is the proposed improvements to Camp Street to provide a more attractive and pedestrian friendly access to the Molineux Quarter. This could be referenced in the plan.

Camp Street enhancements are identified in Figure 24 and Table CA6B. Para 4.7.2 summarises the overall approach and it is not appropriate to replicate proposals set out elsewhere in the Plan.


The University of Wolverhampton is generally supportive of Policy CA6 and accompanying text. With regard to student accommodation, the University’s current accommodation is gated to provide a safe environment for students and so the last sentence of para 4.7.4 should be deleted.

Agree that the proposed change represents current arrangements.

Para 4.7.4: Student accommodation will be an important element in future housing development within the University Quarter. It is important that this is supported by vibrant facilities. Gated student accommodation will not be permitted as this will not contribute to the permeability of the area.


Please note that the University will progress a proposal to change the status of Camp Street from unrestricted highway to a more pedestrian friendly environment with restricted access for vehicles and removal of all on-street parking in order to deliver improvements to the public realm.

Noted.


Minor amendments are suggested to the ‘consultation responses’ text to clarify that the University Quarter is part of the wider Molineux Quarter.

The Molineux Quarter is closely related to the University Quarter but is identified as a different Character Area in the AAP.

18 The Theatres Trust The AAP should acknowledge the function and contribution that the Arena Theatre (which is part of the University) makes as part of the cultural quarter

Agreed. Para 4.7.1 after first sentence add: “The University provides a

94


number of facilities that perform an important function and contribute to the vitality of the city centre, including the Arena Theatre”

Policy CA7 Molineux Quarter


4 Historic England Para 4.8.7 should set out how development will respect the significance of the restored Molineux Hotel, Grade II* as set out in Table CA7A. Support para 4.8.8, though it would be beneficial to include this within the policy.

Table CA7A is linked to Policy CA7 and therefore this text does not need to be repeated in the policy itself.


The University of Wolverhampton is generally supportive of Policy CA7 and accompanying text. Minor amendments are suggested to the policy text to make clear that the quarter also includes the University.

The Molineux Quarter is closely related to the University Quarter but is identified as a different Character Area in the AAP.

Policy CA8 St Peter’s Cultural Quarter



Land to the north of Wolverhampton City Centre Police Station is identified as development opportunity 8c. Therefore request that proposals for this site protect the operational requirements of the Police Station.

Agree. Add to “Further Information” text in Table CA8A, for site 8c: “Proposals should protect

95


the operational requirements of the City Centre Police Station south of the site.”

4 Historic England Support reference to the need to enhance the setting of heritage assets – should reword to protect, conserve and enhance the significance of heritage assets, including their setting. Delete word ‘important’. There are a number of heritage assets within this quarter - has the Council assessed whether the development opportunities are likely to cause harm to the heritage assets, including the Conservation Area?

The policy sets out a key priority, which is to focus on enhancement of important heritage assets, not all heritage assets. Agree that this should be addressed - see response in General table above.

Amend Policy CA8 to state: “… (c) Enhancement of the character or appearance of the Wolverhampton City Centre conservation area and ….” Amend para 4.9.1 to state : “”The St Peter’s Cultural Quarter is an important and attractive part of the City. This area includes The majority of the quarter is covered by the Wolverhampton City Centre conservation area and forms part of the historic core… “ Amend para 4.9.2 to state: “… which can accommodate a mix of uses in landmark locations

96


whilst respecting the historic character and local distinctiveness of the conservation area setting.” Amend Table CA1A Further Information: For site 8a “.. Proposals should improve the public realm and enhance the setting of the conservation area and nearby heritage assets such as St Peter’s Church, including by maintaining important views.” ; For site 8b add to end: “…in keeping with the setting of the adjoining conservation area.” For site 8c “Potential for mixed use development and re-use of the locally listed Express & Star building which respects the conservation area setting, through rationalisation...” For site 8d add to end: “…in keeping with the setting of the adjoining conservation area.”

18 The Theatres Trust The AAP should acknowledge the function and contribution that the Arena Theatre (which is part of

Noted. The Arena Theatre falls within CA6: University Quarter.

See proposed change to CA6 above.

97


the University) makes as part of the cultural quarter Another important issue for the Cultural Quarter, and indeed for other community and cultural facilities such as music venues and pubs throughout Wolverhampton, is to ensure that in encouraging mixed use and residential development, this does not impact on the viability of these existing community and cultural facilities. Para 123 of the NPPF and the Planning Practice Guidance on Noise make it clear that unreasonable restrictions should not be placed on existing businesses, such as noise abatement notices, because of new residents. Therefore the AAP should strengthen guidance to ensure new development is designed to ensure that conflicts do not arise and Wolverhampton’s cultural facilities can continue to operate and expand.

Agree that noise is a potential issue for residential development in the City Centre. Although the NPPF, Planning Practice Guidance on Noise and BCCS / UDP policies provide sufficient policy detail to deal with such issues effectively on a case by case basis, it is appropriate to clarify the potential issues in the supporting test for Policy CC7.

Add to end of para 3.2.15: “This is particularly important to protect the operation and viability of cultural and community facilities.”


Support policy, which will see continual enhancement, protection and promotion of heritage assets in this area.

Welcomed

31 &

56 St Peter’s Collegiate Church & Resident

Table CA8A - remove St Peter’s Car Park (Site ref 8a) from schedule, because of long-standing Council agreement with St Peter’s Collegiate Church to provide car parking for worshippers (unless suitable alternative agreed), and for evening use by patrons of Arena and Grand Theatres, Lighthouse and other City Centre visitors, also because development would ruin prospect of two of City’s most important Listed Buildings, Giffard House and Molineux House, and also their “open square” relationship with University, St Peter’s Church and Civic Centre – this open square idea could be improved upon with suitable treatment.

The AAP seeks to ensure no net loss of parking spaces across the AAP area, as set out in para 3.1.46. Parking charges are not within the remit of the AAP. It is important that the AAP provides a flexible approach by identifying a portfolio of sites for a mix of uses that could help deliver investment, jobs and regeneration in the City Centre. A viability study has looked at the site and concludes that

Add under “Appropriate Uses” and “Development Capacity” entries for Broad Street Car Park (site ref 8b) “including public car parking”

98

Remove Broad Street Car Park (Site ref 8b) from schedule in view of Sunday overspill parking needs for St Peter’s Collegiate Church, use by Temple, Mosque, Westbury Chapel, long-stay use by railway travellers, daytime and evening use for Art Gallery, Arena and Grand Theatres, Lighthouse and other City Centre visitors.

alternative uses coming forward at St Peter’s Car Park would be viable. The AAP proposes the development of high quality multi-storey car parks to improve the accessibility of the city centre to visitors as advised in the Commercial Sites Assessment Study (para 2.1.9). These multi-storey car parks will provide for the needs of new development and will provide for spaces displaced through the development of a number of surface car parks across the city centre. Any car parking spaces displaced through development would only be carried out on a phased basis to ensure that there is a balanced network of car parks across the city centre to meet a variety of needs. It is recognised that ‘destination’ parking can play a role in serving important facilities in the City Centre, such as those within CA8 St Peter’s Cultural Quarter. A Car Parking Strategy is being undertaken, which will include investigating the issue of destination parking. In terms of other existing surface level car parks in St

99

Peter’s Cultural Quarter, Table CA8A identifies the need to include some public car parking at the Broad Street Car Park development opportunity (8b) as part of the future redevelopment of the site. New car parking will also be provided at the Interchange (site 3a), which is a short distance from St Peter’s Character Area. There are existing car parks in this character area which are not proposed for redevelopment in the AAP e.g. at the Civic Centre. WCC recognises the historical importance of St Peter’s Collegiate Church and the important role it plays in serving the community. The Council are committed to working proactively in partnership with church to assist in addressing any accessibility issues. If St Peter’s Car Park does come forward for development in the future this could include investigating potential alternative car parking provision which could be utilised by the church.

44 Resident The historic quarter is more than a museum it also has a cultural living gem in St Peter’s Church, one of three main churches (together with Catholic Church of St

See response to ID 31 & 56 above.

See response to ID 31 & 56 above

100

Peter and St Paul and Darlington St Methodist Church) in Wolverhampton witnessing to the thousand year history of Christianity. The current musical tradition which continues as a core part of the services at St Peters depends on collaboration of parents who are dependent on St Peters Car park - I doubt their attendance if they cannot access the church easily by car. Any sale of local car parking will only be supported if subsequent building incorporates 100 car spaces which are free during service times. Perhaps it would be possible as with the new Sainsbury’s development to register Church car registrations as creditable for 2 hours to keep the church alive.

49 Resident Delete references to development of St Peter’s and Broad Street car parks. The “heritage assets” (St Peter’s Church, Grand Theatre, Wolverhampton Art Gallery, the Lighthouse etc) cannot be maintained unless it is easy for people to visit them. Removing easy car-parking from this area will make people (particularly the elderly) unable to use and enjoy these places, and a reduction in the number of regular visitors will mean a reduced income for these places.



53 Resident Concerned about people who worship at St Peter’s Church. Some have to travel by car as buses are fewer on Sundays. I will not pay parking fees and would attend less often or by bus.



52 Resident Note swathes of red development opportunities in St Peters Cultural Quarter. Local free or low cost car parking is needed to encourage people to visit and stay to use and explore Wolverhampton’s cultural sites. No more development opportunities are needed at this time, there are already numerous empty office buildings. Need to encourage footfall into the city



101

centre. Nearby centres offer free parking (Bentley Bridge/Merry Hill). Parking charges are having a devastating effect on attendance /activity at St Peters Church – a jewel in Wolverhampton’s crown.

56.

Resident

Policy wording Policy CA8 (c) after “St Peter’s Church” add “, which is the Civic and Parish Church of the City and the City Centre’s most important architectural and historical building” Para 4.9.1 after second sentence add: “St Peter’s Church, in addition to its role as Parish and Civic Church, opens its doors daily to members of the community of all faiths and none.” Typographic suggestions to para 4.9.1

The suggestion is considered to be too detailed information to be included in the policy wording. The importance of St Peter’s Church is already noted throughout the document, including in the naming of this Character Area and e.g. reference in para 4.9.1 This suggestion is considered too detailed to be added to this paragraph Noted

See change ref 13 Table 3 below.

Policy CA9: St Johns and St Georges


4 Historic England Support reference to the historic environment and reference to importance of the historic environment in this quarter, including para 4.10.2. Recommend the inclusion of protecting, conserving and enhancing the significance of heritage assets as well as the historic character of the area. Support retention of listed building in Site 9a - how will

Welcomed. As there is little change envisaged in this area over the Plan period it is not considered necessary to add to the Policy further. The former St George’s Church

102


this be protected and conserved? Will there be additional design guidance / a Masterplan as in other character areas?

forms part of a former conversion scheme to a supermarket. Depending on the future use of the site a range of designs may be acceptable and producing specific design guidance or a Masterplan is not considered appropriate.

38 Spectrum Investment Management

We act on behalf of the freehold owners of the St. Georges Parade site formerly occupied by Sainsburys. This is a gateway site and we would not wish to be constrained by the adoption of the AAP in a difficult market. Comments in respect of ‘it is important that the height and design of development protects and respects views of the Royal Hospital and its listed building / conservation area setting’ are noted, but it is important that overly restrictive AAP policies could make any potential schemes and uses unviable.

The Policy provides a flexible and positive framework to secure the reuse and / or redevelopment of the site. The Royal Hospital site (RHS) is a key heritage asset of significance to the whole of the City Centre and the redevelopment of the St. Georges Parade site has the potential to significantly impact upon views of the RHS from the surrounding area. For increased flexibility and clarity (and to reflect proposed changes to Policy CC1(d) - see Appendix – separate document) it is proposed that reference is made to the site’s potential to be re-occupied by a foodstore operator and that B1(a) office uses would be acceptable at this location.

Para 4.10.2, third sentence after “active use” add “which could include being re-occupied as a foodstore” Table CA9A under “Appropriate Uses” entry after “offices” add “(B1(a)”

48 Our Own Future A possible site for a museum is the former Sainsbury's (which could possibly include a second floor) - near

Policy CA9 mentions the potential for community uses at

103


the ring road and a big car park. the St George’s Parade site, which could include a museum.

Policy CA10: Blakenhall & Graiseley


4 Historic England Support reference to historic environment in h). Consider replacing ‘preserving’ with ‘protecting, conserving and enhancing the significance of heritage assets and the historic industrial environment’. Support para 4.11.4 and concept of heritage led regeneration. It is important that the policy adequately refers to heritage assets and that appropriate detail is provided about the need for sensitive restoration /development to ensure the importance of this area is protected.

The policy sets out a key priority, which is to focus on the historic industrial environment. It is considered that the existing policy wording, taken together with a strengthened Table CA10A, will adequately address specific heritage issues.

Amend Table CA10A Further Information for site 11a to: “… Any alternative development will need to respect the local list building, address the Penn Road…”

25 Blakenhall Local Neighbourhood Partnership and Action Community Forum

The work of ABCD (2001-11) has not been sustained

The ABCD legacy of environmental improvements, housing renewal and community involvement is fully reflected in the AAP. Reference is made acknowledging the work undertaken by ABCD in paras 4.11.6 & 4.12.2. The AAP will provide a planning steer to help deliver future regeneration in Blakenhall. WCC and partners are committed to comprehensive city centre

104


Extend AAP boundary southwards covering Dudley Road and footpaths as an important gateway into the City Centre, to help deliver enhancements as part of the parking/street cleaning & maintenance and address traffic flow issues

regeneration as a top priority. This approach has involved the careful prioritisation of certain sites and areas for investment, both public and private sector, and securing potential Black Country SEP funding. Details are set out in the Delivery Plan. It would not be practical or effective to extend the AAP boundary to include just the Dudley Road and footpaths. As this land is adopted highway it would not be subject to planning regulations, including any policy that might be included in the AAP. It is appreciated that footpath quality is an issue being raised by the LNP. Whilst it is not within the remit of the AAP it is recognised that the AAP needs to be deliverable as part of a joined-up, collaborative approach with stakeholders, alongside other delivery mechanisms. Footpath, associated enhancements and addressing traffic flow issues can be effectively delivered by other mechanisms, such as work undertaken by the Council’s Street Scene and

105


Issue of fly-tipping Support the inclusion of The Old School site on Dudley Road, and St. Luke’s Church within the AAP boundary Support Policy CA10 (f) An enhanced pedestrian crossing at the ring road junction with Snow Hill & St. John’s retail park will encourage linkages between Dudley Road shops and the City Centre

Transportation sections. Adopted highway maintenance is undertaken as part of the Council’s planned highways maintenance programmes. The draft AAP highlights the importance of Dudley Road as both a key gateway corridor (Policy CC6, Fig 6) and a key frontage (Policy CC8, Fig 8) to the City Centre. This issue is addressed by the City Environment section of the Council and does not fall within the remit of the AAP. Welcomed Welcomed The current crossing is considered to be performing well and a toucan crossing will be provided by 2016. The identified priority is to provide a new pedestrian crossing at Ring

Para 1.5.5 add new sentence to end “The AAP is part of a collaborative approach and a comprehensive package of measures to support the sustained regeneration of the city centre.”

106


Any potential loss of existing (and rundown, poor quality) cheap all-day car parking will inevitably have an impact on local on-street parking. Support the attention and recognition to the importance of Blakenhall’s historic Victorian buildings

Road St John’s (draft AAP Fig. 5 Ref. T6), which will enhance linkages between the City Centre and Blakenhall. A Car Parking Strategy for the city centre is being undertaken. Policy CA10 Site 11e identifies surface level car parks at Dudley Road/ Bell Place as suitable for residential development. This will help meet housing requirements, and enhance the Dudley Road key gateway corridor (Policy CC6, Fig 6) and key frontage (Policy CC8, Fig 8). Any existing, on-going or future issues with on-street parking in the area can be considered within the Council’s capacity to address road safety, congestion, enforcement issues and development impacts. Parking requirements for future residential developments around the Blakenhall area will be considered based upon accessibility, local impact and other factors in accordance with saved UDP Policy AM12. Welcomed

107


to the area. Wish to see enhanced opportunities for the development and delivery of “walking trails” around the area particularly in relation to Blakenhall’s role in the early development of manufacturing. Support reuse of historic manufacturing buildings for residential and for commercial use, as long as they are not lost to the area or that their visual appearance is not diminished by new development or changes of use. Other non-manufacturing historic buildings within the character area should be retained and nearby developments should not detract from their appearance and local importance. Support need for additional residential developments, welcoming the proposal to create housing at the former Sunbeamland factory (Development Opportunity 11a). New housing should focus on providing social housing and properties for purchase, rather than private rented housing.

The AAP supports enhanced linkages from Development Opportunity sites 11b and 11e to Graiseley Recreation Ground. The AAP would not preclude the community bringing forward walking trails, such as those provided by ABCD. Welcomed. Listed/ locally listed buildings are identified in the draft AAP and the determination of individual applications will include giving due weight to the importance of such buildings, as emphasised in Policy CC9 – Protecting and Enhancing Historic Character and Local Distinctiveness. Welcomed The BCCS sets a requirement for 25% affordable housing and it was decided not to set a different target in the AAP area following the Issues & Options consultation stage. The planning

108


The provision of 490 new homes would have a positive effect on the viability of local shops and

community facilities but local educational needs and

facilities will inevitably need to be reviewed and will increase pressure of the already strained local on-street parking. There appears less of a focus on local employment and training opportunities, particularly for local young people and for ‘new arrivals’ to the area. Existing employment areas around St. John’s / Ablow Street etc. – “The Warehouse Quarter” - should be retained and improved, rather than some of the area being cleared of small units and replaced with new residential units.

process is unable to restrict the future sale of market housing for use as private rented properties. Education needs are assessed on an on-going basis and if the need for additional education provision does arise this will be met (as noted in Table 35). At present, there is not considered the need to allocate a site for additional education provision in the AAP. Any existing / on going / future issues with on street parking in the area can be considered within the Council’s capacity to address road safety, congestion, enforcement issues and development impacts. The draft AAP seeks to strike a balance between residential provision and retention of employment land. There is a strong emphasis on local employment land provision, with Policies CC4 and CA10 identifying 31ha of land for protection in the Graiseley and Blakenhall Character Area. This includes identifying 14ha of Employment Land being retained in the Warehouse

109


Issue of delivery due to lack of money.

Quarter (site ref. LQE3), as set out in Table CA10B. Therefore the majority of land currently utilised for employment activity in the Character Area are proposed to be retained. BCCS Policy EMP5 covers local recruitment and training. Local residents of Blakenhall & Graiseley are in close proximity to access the employment opportunities provided by the City Centre. The AAP is one part of the jigsaw to deliver regeneration, and the policies are aimed at facilitating and maximising investment and jobs to the benefit of the local community. Detailed delivery issues are covered in the Delivery Plan.


Support recommendation to designate and protect local character.

Welcomed

30 Blue Square Penn Road Ltd

Sites 11f and 11g should not be allocated for housing-led development, as this conflicts with the current proposal for a major car showroom development which would make use of both sites. The sites have been vacant for many years and there is little prospect of residential development, which could be accommodated on other sites. The sites are located in an established retail and commercial location and the extant planning consent for non-food retail on site 11g

Sites 11f and 11g now have permission for a car showroom. Therefore agree that the allocation for these sites should be amended to reflect this potential use. However, it is not guaranteed that the permission will be implemented, therefore the AAP should indicate other

Amend Table CA10A to read: For site 11f: Appropriate Uses – “Car showroom or residential” Development Capacity – “Car showroom or 80 homes (high density)” Further Information –

110


has been implemented. Housing development could also constrain existing businesses nearby.

suitable uses for the sites, which include residential as this could be designed to reduce any impact on adjoining businesses to acceptable levels.

“2015 permission for car showroom. Any alternative development . …” For site 11g: Appropriate Uses - “Car showroom, retail or residential-led development” Development Capacity – “Car showroom or up to 5,600 sq metres restricted non-food retail floorspace or 60 homes (high density) Further Information – “Extant permission for restricted non-food retail floorspace and 2015 permission for car showroom. …”

Policy CA11 All Saints


4 Historic England Support reference to need to retain listed buildings and have respect to the conservation area. Recommend including a clause that sets out the need to protect, conserve and enhance the significance of heritage assets including the specific listed buildings and the conservation area.

Welcomed. BCCS and UDP policies cover this general requirement.

111


Para 4.12.5 consider amending historic buildings to ‘heritage assets’.

The sentence particularly refers to buildings rather than assets more generally.


Support recommendation to designate and protect local character.

Welcomed

26 Tesco (Nathaniel Lichfield & Partners)

The Council can help Tesco deliver the development the City needs by enabling a range of potential uses on the former Royal Hospital and bus depot sites which it can market to developers - the greater the flexibility the greater the potential for success. Agree with particular aspects of the Vision for CA11, which needs to emphasise the importance of links to the City Centre “core”. The Character Area and Tesco sites in particular are suitable for a mix of retail, residential, leisure and commercial uses, as well as education. Student Accommodation would be suitable. A number of complementary uses, including food and drink, community, car showroom and petrol filling station should be listed in the policy 100 houses is likely to significantly underestimate the housing potential of the Tesco sites and wider Character Area. A 2007 planning application (which received a resolution to grant permission), demonstrates the potential to deliver up to 370 dwellings, and this could increase further if the Royal Hospital Main Building included residential provision. In light of Tesco’s decision not to proceed further with permitted large retail store scheme, suggest that CA11(b) be deleted. However, it would be helpful to include indications of minimum development potential with respect to various uses, and this should

In light of the announcement by Tesco on 8th January 2015 that they will not be proceeding with delivering a foodstore at The Royal Hospital site, and representations to the AAP Draft Plan, the wording of Policy CC1 ‘Meeting Shopping Needs’ and Policy CA11 ‘All Saints’ have been revisited. The proposed wording for Policy CC1 reflects an amended approach to meet convenience needs in the city centre. Policy CA11 recognises the potential of the site (11a) to provide other primary uses, specifically residential and education, and the proposed amendments also reflect suitable subsidiary and complementary uses, together with key urban design principles.

See amended Policy CA11 wording in Appendix (separate document).

112


recognise that a commercially viable scale of development would need to be achieved. “Justification” section to be updated to reflect changes to the mix of suitable uses and that sites are within the city centre boundary. Support reference to “high and medium density housing” as it is important to produce a ‘landmark’ development as a ‘gateway’ into the city centre. Reference to the importance of views to St John’s and St Peter’s churches should be deleted. Importance of improving views of the listed hospital building, particularly from Bilston Road should be included. ‘Development Outputs’ should be updated and include minimum development potential with respect to various uses. Table CA11A should be updated to reflect the various suitable uses. ‘Consultation Responses’ should be updated. Fig 34 mapping of listed buildings should be updated to reflect the recent demolitions that have taken place on the site. The mapping colour for listed/ locally listed buildings is the same as the CA6 University Quarter and is confusing.

Consultation responses are not proposed to be included in Publication AAP. The AAP cannot alter a listed building designation – boundaries are provided on plans for information only. Two different shades of blue are used for the mapping so no change is required.


Given Tesco’s announcement that they will not be proceeding with developing The Royal Hospital site it is unlikely that a foodstore will come forward at this location. The Council should actively revisit proposals for this site, along with Tesco, to look at alternative options for its regeneration which contribute to meeting the wider needs of the City Centre

In light of the announcement by Tesco on 8th January 2015 that they will not be proceeding with delivering a foodstore at The Royal Hospital site, and representations to the AAP Draft Plan, the wording of Policy CC1

See amended Policy CA11 wording in Appendix (separate document)

113


‘Meeting Shopping Needs’ and Policy CA11 ‘All Saints’ have been revisited. The proposed wording for Policy CC1 reflects an amended approach to meet convenience needs in the city centre. Policy CA11 recognises the potential of the site (11a) to provide other primary uses, specifically residential and education, and the proposed amendments also reflect suitable subsidiary and complementary uses, together with key urban design principles.


As Tesco, the intended occupier, have withdrawn from the site it is necessary to revisit the proposals for The Royal Hospital to ensure the regeneration of this key gateway site can be brought forward without compromising the objectives for the shopping core.

In light of the announcement by Tesco on 8th January 2015 that they will not be proceeding with delivering a foodstore at The Royal Hospital site, and representations to the AAP Draft Plan, the wording of Policy CC1 ‘Meeting Shopping Needs’ and Policy CA11 ‘All Saints’ have been revisited. The proposed wording for Policy CC1 reflects an amended approach to meet convenience needs in the city centre. Policy CA11 recognises the potential of the site (11a) to provide other primary uses, specifically residential and education, and the proposed

See amended Policy CA11 wording in Appendix (separate document)

114


amendments also reflect suitable subsidiary and complementary uses, together with key urban design principles.

48 Our Own Future The Royal Hospital site would be a good location for a museum depending on any obligations Tesco has to redevelop the site. It would be easy to access for schoolchildren.

Policy CA11 mentions the potential for community uses at the Royal Hospital development site, which could include a museum.

Policy CC12 Infrastructure, Delivery and Monitoring



Request that the police are included in the list of partners for provision of essential infrastructure and that Figure 35 Infrastructure Requirements should include delivery of police infrastructure, by the police authority and developers.

There is no evidence that additional police infrastructure is required to support the development proposed in the draft City Centre AAP.

3 Natural England Support the requirement for developer contributions towards environmental infrastructure.

Welcomed


Welcome inclusion of canalside improvements in Figure 35.

Welcomed

115

Appendix E

ID Respondent Summary of Respondent Comments Council Response Proposed Change to

Draft Plan


Note the emphasis of the AAP to aligning the Primary Shopping Area (PSA) with the Shopping Core Character Area, resulting in a contraction of the current PSA. Highlight that, in accordance with paragraph 7.34 of the Holliss Vincent Retail Update Study, nothing should prevent the existing units (or any subsequent replacement) removed from the PSA continuing to perform their established retail use.

As observed by Hollis Vincent, a contraction to the PSA would not prevent existing units that would subsequently fall ouside the PSA from continuing to operate in their current established retail use. Consistent with national guidance, any subsequent future planning decisions would be taken in accordance with the development plan unless there are material considerations that indicate otherwise. Therefore, for example, if a leisure-led mixed-use application with a retail element came forward in the Westside Character Area in the future, this retail element would accord with draft Policy CA2.

116

Table 3: Proposed Changes to Draft Plan in response to up-to-date information, changing circumstances

and to correct errors

Change Ref

Reason for Change Proposed Change to Draft Plan

1 The boundary of Development Opportunity site 4m was drawn in error and should have included the adjoining triangle of land including the listed Former Butter and Cheese Warehouse and locally listed 16B Union Mill Street.

Amend boundary of Development Opportunity 4m to include Former Butter and Cheese Warehouse, Union Mill Buildings and land at Union Mill Street. Amend Table CA4A row 4m to read: Former Stamping Works and Butter and Cheese Warehouse, Horseley Fields; 2.16 2.39

2 The Draft Plan included some sections (consultation responses; options considered but not brought forward; sustainability appraisal) which were necessary to show how the Plan had developed, but which are not appropriate to include in the final Publication Plan.

Delete all parts of the document with the following headings: Consultation Responses Options Considered but not brought forward Sustainability Appraisal Delete Appendices B and C and renumber remaining Appendices.

3 The Monitoring section (para 1.5.9) did not include a table showing how delivery of each policy would be monitored e.g. through BCCS indicators or through the monitoring of delivery of individual sites.

Include the following text / table under existing text in para 1.5.9: “The policies in this Plan will be monitored through the following:

AAP Policy Indicator

CC1 BCCS LOI CEN1/2/3

CC2 BCCS LOI CEN1/2/3

CC3 BCCSLOI CEN1/2/3

CC4 BCCS LOI EMP3b / DEL2c

CC5 Delivery of key education and learning proposals.

CC6 BCCS LOI TRAN2/4a/4b

CC7 BCCS LOI HOU1

CC8 BCCS LOI ENV3/3a

CC9 BCCS LOI ENV2

CC10 BCCS LOI ENV5

CC11 BCCS LOI ENV3b/7

CC12 Delivery of infrastructure will be monitored through the AAP Delivery Plan and relevant indicators for individual policies.

117

4 The Executive Summary, Providing Your Comments, Introduction and Part E – Getting Involved and Next Steps need to be edited to reflect the move from a Draft Plan to Publication stage.

Executive Summary “Wolverhampton City Council is has been working with…” “The AAP will identify identifies which…” “Permission has been granted …. Citizens make the most of future growth and regeneration.” “It is vital that The AAP builds on these successes and provides a strong…” “The AAP will belong belongs to the local community. A consultation strategy has been developed which sets out how The Council and its partners will engage have engaged with local people… throughout the AAP process on an on going basis.” “This Draft Plan …-January 2014.” “The AAP will build builds on strategies already in place…” “The AAP will be is flexible.” “This will be has been achieved by giving a sufficiently…” “It must be is also be flexible enough…” “This draft Plan sets out proposals and policies…” “The draft Plan builds on the extensive work that we have carried out …. Or hand in your form at Reception 24 (2nd floor of the Civic Centre Thank you” Introduction 1.1.1 “.. (the AAP) is being has been produced…” 1.1.4 “Three Area Action Plans (AAPs) are being brought forward for Wolverhampton to provide a more detailed…” 1.1.5 “…areas covered that will make up…” 1.1.6 “..they will allocate land for…” “.. and will help direct future development…” “… Neighbourhood Plans will have the same lifespan…” 1.3.1 “The draft Plan has also…” 1.5.6 “The boundary has been slightly altered… Board School buildings.” 1.5.8-10 “The City Centre AAP ...Commercial Sites Assessment Study.” 1.5.11 “The draft Plan will reflect reflects the following key messages…” Vision 2.2.2 “A number of responses…set out in Part C.” “Part E – Getting Involved and Next Steps

118

…. Adoption of AAP – June 2016” Part D – Infrastructure, Delivery and Monitoring Delete para’s 5.1.7-8 and replace with new para 5.1.6: “A Delivery Plan has been produced, with input from infrastructure providers, developers and other key organisations, which demonstrates how the development opportunities and supporting infrastructure in the AAP will be delivered and addresses issues of viability, funding and phasing.”

5 Policy CA2(a) - reference to Darlington Street inadvertently omitted

Policy CA2(a), first sentence add “Darlington Street”

6 Site references need to be amended so that they follow sequentially and relate to Policy references.

Amend site references throughout the AAP accordingly.

7 Site 11a Former Sunbeam Factory is currently partially under construction with the first phase of 30 homes due to be completed by the end of 2015.

Amend para 4.11.4 to state ”… Penn Road Island is a development opportunity which is partially under construction with an extant planning permission.” Amend Table CA10A Further Information for site 11a to “Extant residential permission. Partially under construction. …”

8 The central part of site 2a(i) Westside (the “Youth Zone”) is substantially completed and should therefore be removed from the allocation.

Amend boundary of 2a(i) to exclude Youth Zone site and amend Table CA2A for site 2a(i) to Size (ha): “1.22” and Development Capacity: “Around 15,000 sqm of floorspace”. Amend para 4.3.5 to state: “… This area contains the site of the proposed Wolverhampton Youth Zone …”

9 Part of site 4k is in the same ownership as the adjoining part of site 3a (former Old Steam Mill|) and these sites are likely to be developed together. Therefore site 3a should be amended to include the relevant part of site 4k and the Character Area boundaries amended accordingly.

Amend boundaries of site 3a and 4k and City Interchange & Commercial Gateway and Canalside Quarter Character Areas. Amend Tables CA3A and CA4A to reflect changes in Size (ha) and Development Capacity for sites 3a and 4k.

10 Work has been commissioned to consider detailed master planning for Westside and Southside, which may provide more detail on the location for linkages and public realm / environmental improvements.

On the key for all relevant plans in the AAP insert: “(indicative location)” after the following designations: Public Realm Improvement; Environmental Improvement; New / Improved Linkages. Add to end of para 3.1.42: “The proposals shown on Figure 6 include specific transport proposals as listed in figure 5, and also other new / improved linkages which are referenced in Part C.”

11 Tables in Part C need to cross-refer to Amend Tables in Part C to cross-refer to relevant BCCS and UDP policies.

119

relevant BCCS and UDP policies.

12 Further work has been undertaken regarding potential archaeology for development opportunities using the Wolverhampton Historic Environment Record and available historic map sequence, which needs to be reflected in appropriate changes to Part C.

Add “Potential archaeological interest.” to the Further Information column for the following development opportunity sites: 1b(i) 1b(ii) 1b(iii) 2a(i) 2a(ii) 2a(iii) 3d 4b 4c 4f 4l 4m 4n 6b 8a 10a 11f 11g 11h

13 Consistency required in capitalisation of various terms throughout document (in response to comments by ID 56)

Throughout document use the following capitalisation: “City Centre AAP” when referring to the AAP “city centre” when referring to the city centre area “City” when referring to the City of Wolverhampton “ring road” when referring to the city centre ring road

14 Environment & Design / Transport Proposals

Ensure there is no duplication and standardise wording throughout document.

15 Policy CC9 and justification requires clarification that parts (a) and (b) relate only to Historic Landscape Characterisation (HLC) sites, and not other heritage assets covered by national and local plan policies, including listed & local list buildings and conservation areas. Also part (b) needs to conform with NPPF wording.

Amendments to Policy CC9: “… features identified in the City Centre Historic Landscape Characterisation Study (HLC sites)…” “(a) Development proposals affecting HLC such sites should…” “(b) Development that would result in substantial harm to or demolition of a HLC site heritage assets will not be permitted unless, in addition to any requirements contained in national guidance, either it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss, or all of the following criteria are met:” Amend para 3.3.10: “…covering a third of the AAP area, which are subject to relevant national and Wolverhampton Local Plan policies. Amend para 3.3.15: “…unrecognised heritage assets (“HLC sites”) which are not covered by a listed or local list designation. These include buildings…” “..(Category 3). Policy CC9 sets out the approach towards protecting these HLC sites, and the sites are detailed in Part C…”

16 Following progress on Canalside Quarter Delete T15 from Figure 5 and Table CA4C, and renumber T16.

120

infrastructure work, a bridge is not required to access the former Crane Foundry site.

Amend Table CA4A, further information for former Crane Foundry site: “To be accessed via new canal bridge from Union Mill Street or via tunnel to link up with Qualcast Road.” Remove T15 arrow from all plans. Amend Policy CA4: “… strong canal frontage and link to the Interchange, centred on a new canal bridge / public square / leisure hub” Delete para 4.5.4 last sentence referring to bridge Amend Table CA4B Union Mill Street Public Realm, further information to: “Creation of public spaces to provide a quality setting for the new bridge and listed building conversion at the Former Stamping Works.”

Appendix: Proposed Changes to Policies CC1 and CA11 (see separate document)

Documents

Wolverhampton City Centre Area Action Plan (AAP) Draft ... · Strategy. The focus of office provision at the Interchange, together with the strategy to support mixed-use development