Support

Representation ID: 945

Received: 21/11/2024

Respondent: Dennis R Whittaker

None.

Comment

Representation ID: 1022

Received: 27/11/2024

Respondent: Glen Dimplex Group

Agent: Glen Dimplex Group

Policy DLP21 - Other Employment Areas Policy DLP21 refers to sites outside of designated employment areas, identifying them as 'Other Employment Areas'. The policy states that these identified sites will be either:

CBRE 3(a) retained and enhanced for industrial employment uses within Use Class E(g)(ii), E(g)(iii), B2 or B8;

(b) be redeveloped for housing; or

(c) where appropriate, be developed for community, entertainment, food and drink, or leisure and recreation uses.

Under Part 2 of the policy a number of criterion for circumstances where proposals are put forward for an alternative development under points b and C.

As currently worded, Part 2 is ambiguous whether all of the criterion are required to be met to demonstrate that the loss of an employment use is acceptable, or whether one of them needs to be satisfied. In our previous response to the Regulation 18 consultation, we advised that this should be amended for the next version of the Plan to ensure that this is clear. We do not consider that all of the criterion should be required to be satisfied, but rather one or more. This is because to satisfy all of the criterion may potentially lead to conflicting positions, resulting in an overly restrictive policy. This would, in our opinion, result in the policy not being positively prepared, effective or justified. We therefore suggest the following additional wording is included to provide clarity (additional wording shown underlined):

"Development for uses under 1(b) or 1(c) will only be acceptable where there is robust evidence to demonstrate to the satisfaction of the council that one or more of the following criteria have been met: [...]"

In terms of the consideration of this policy against the legal tests of soundness, we advise the following:

Positively prepared - whilst this policy could generally support the OAN and reduce the requirement for unmet need to be addressed through the duty to co-operate, without clarity it could prevent or delay deliverable housing sites coming forward therefore making it more challenging to meet the OAN, particularly when relying on windfall developments.

Effective - this policy, without the proposed additional wording set out above, could prevent or delay the delivery of housing sites if all of the criteria is required to have been met.

Justified - it is not clear why all of the criteria would be required and therefore is not an appropriate strategy.

Comment

Representation ID: 1219

Received: 05/12/2024

Respondent: Walsall Council

Clause 1 c. of policy DLP21 refers to community, entertainment, food and drink, or leisure
and recreation uses. These are likely to be main town centre uses so should be located in
centres rather than in edge of centre or out of centre sites as this clause and paragraph
9.47 would appear to support. We understand however that the policy is only intended to
be used to allocate specific employment areas and to ensure that these uses are directed
to sequentially acceptable sites where they cannot be accommodated within the respective
centres.

Object

Representation ID: 1222

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

. Within the emerging Local Plan Review the council should focus on protecting existing employment land sites (including lower quality employment land sites which are currently struggling during the severe economic recession) in order to ensure that there is a sufficient ready supply of employment land available to meet the Dudley Borough’s current and future employment land needs. Essentially to ensure that local communities have a supply of local jobs within the inner urban area close to existing established residential communities. This plan-making approach will help to ensure the delivery of sustainable



communities consistent with guidance reinforced in paragraph 35 (indent d) of the Revised NPPF (December 2023). The proposed spatial planning policy approach of focusing 10,470 new homes into the inner urban area will result in the loss of employment land sites within the inner urban area, which could help to positively contribute towards meeting future local community employment needs. All types and condition of employment land sites should therefore be safeguarded within the inner urban area in the emerging Local Plan Review, and significant new housing development focused towards a housing-led sustainable urban extension in the borough’s low quality Green Belt countryside at land located south of Racecourse Lane, Norton, Stourbridge. The position is perfectly clear, there are now sufficiently robust exceptional circumstances and planning policy grounds now in place for the LPA to now consider Green Belt release within this emerging Local Plan Review, in order to help protect and maintain a sufficient and adequate supply of employment land within the inner urban area. To help ensure that there is a sufficient supply of locally-based employment land opportunities provision available to meet local community urgent needs, during a severe prolonged economic recession and cost-of-living crisis.

43. This is particularly relevant given that the Black Country’s traditional manufacturing industry has suffered extensive decline during the last 60 years. There is a need to future proof existing employment sites within the urban area with new, more resilient employment uses to help meet the local communities needs. The economic vitality of the inner urban area needs to be protected as the local area emerges from the post COVID-19 fragile economic recovery.

. The Sustainability Appraisal (SA) has failed to adequately and robustly consider the loss of employment land sites within the inner urban area and has also not thoroughly investigated Reasonable alternatives – in terms of loss of employment land sites. It is therefore failing Soundness tests in paragraph 35 (indents b and d) of the Revised NPPF (December 2023).

72. Dudley and the wider Black Country sub-region continues to suffer with poor economic regeneration jobs growth in comparison to other parts of the UK. Such as the home counties surrounding London, and places like Oxfordshire, South Warwickshire and Northamptonshire. This should therefore be a key Local Plan priority. The Black Country sub-region is falling far behind other parts of the UK given its continued very weak economic performance, subdued and poor-quality new jobs growth. This is harming local communities. The Index of Multiple Deprivation (IMD) (2019) confirms that: “…19% of people living in the Black Country are in the top 10% most deprived areas…” The Black Country area is experiencing continued and long-standing high levels of unemployment and social and economic disadvantage. Reducing the supply of existing employment land sites within the Dudley Metropolitan Borough within the emerging Local Plan Review will make this situation far worse will eliminate any prospects of significant future economic recovery within the local area. This approach is failing local communities.

Support

Representation ID: 1447

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

**Summary:**

Draft Policy DLP21 outlines the Council’s approach to employment areas not designated as Strategic or Local Employment Areas but still comprising existing employment land. The previous Regulation 18 draft did not distinguish between sites in current employment use proposed for housing, such as the DLP H017 site, but this has now been addressed in the Publication Draft, which is supported. The Council has already assessed and deemed the loss of employment uses on such sites, including DLP H017, as acceptable through the site allocation process and previous adopted policies. Therefore, the policy's recognition of this principle is supported.