Support

Representation ID: 984

Received: 25/11/2024

Respondent: Dennis R Whittaker

Necessary for the well-being of local people.

Support

Representation ID: 1079

Received: 27/11/2024

Respondent: Mr George Morran

Green Belt, Open Space, Areas of Special Landscape
The proposed policies to protect green spaces in Woodsetton are supported, but their success is threatened by budget cuts, limited funding, and reduced community support. The Trust calls for an Action Plan for Sedgley/ Woodsetton, outlining specific actions, responsibilities, and timelines to ensure these policies are effectively implemented, such as urgent action for Hurst Hill Wood.

Object

Representation ID: 1125

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? No

DLP Policies Map should include Local Nature Recovery Strategy.
for ease of reference by planning officers.

Object

Representation ID: 1146

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The DLP must identify more greenfield sites if it is going to deliver Dudley’s own identified housing needs, rather than continuing to rely heavily on constrained brownfield sites that have failed to deliver the homes needed to date and rather than relying heavily on neighbouring authorities to deliver its identified needs when they are similarly constrained – including by Green Belt. Given 18% of Dudley is Green Belt, this will necessitate some Green Belt release. Dudley has acknowledged that its minimum identified housing needs cannot be met if it continues to rely almost entirely on brownfield land within the urban areas. The scale of this deficiency, either on face value in the draft DLP or properly taking into account the factors discussed here which serve to exacerbate it, contributes to the exceptional circumstances required to alter the Green Belt in accordance with Framework (Paragraph 140). Previously, as part of the now defunct Black Country Plan process the Black Country Authorities, including Dudley, acknowledged that Green Belt release would be essential in order to deliver housing growth in accordance with national planning policy. That remains the case, and must be recognised by the DLP.

As discussed above, the inability of Dudley to meet its minimum housing needs is a recurrent strategic planning issue in the Borough and sub-regionally, which requires significant and bold intervention.
With brownfield opportunities becoming exhausted, and in any event failing to deliver, the DLP must identify greenfield and Green Belt release sites within Dudley to meet Dudley’s own housing needs during the DLP period, and beyond.

Persimmon Homes have promoted land at Holbeache Lane for residential development including its removal from the Green Belt to provide a deliverable site to meet housing needs. It was removed from the Green Belt and allocated for housing in the previous draft review of the Black Country Plan – its merits for removal from the Green Belt and allocation for housing remain to this day.

Object

Representation ID: 1171

Received: 29/10/2024

Respondent: St Modwen Homes

Agent: RPS

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Draft Policy DLP49 is unsound as it does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for housing.
As set out in previous responses to the Regulation 18 Plan, RPS on behalf of St Modwen Homes objects to the DLP on the basis that it seeks to provide only 10,470 in the plan period, leaving a shortfall of 899 dwellings, but also a potential shortfall of c.13,000-20,000 under the draft NPPF. The DLP therefore fails to provide sufficient land to meet the minimum housing needs, as per NPPF paragraph 11(b), and will need to ensure that additional housing land is provided through further Green Belt release.
The present version of the DLP Regulation 19 local plan is unsound because:
1. It makes no attempt to provide for sufficient housing (paragraph 1) or meet its housing needs (paragraph 15), contrary to the NPPF;
2. It makes no attempt to meet as much of its housing needs as possible (paragraph 60);
3. The Council has been unable to offload any of its unmet need to its neighbours;
4. The plan is therefore contrary to the NPPF (paragraph 35(d));
5. Self evidently it is not an effective strategy (paragraph 35(c));
6. The strategy is no justified (paragraph 35(b));
7. The District very plainly can physically meet all its needs and leave nearly all of the Green Belt untouched, meaning it has not taken account of or to reasonable alternatives;
8. One key alternative is a version of the Plan which looks to meet its housing needs as set out under the transitional arrangements of the draft NPPF 2024.

Object

Representation ID: 1231

Received: 29/11/2024

Respondent: West Midlands Housing Association Planning Consortium (WMHAPC)

Agent: Tetlow King Planning

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The WMHAPC is disappointed to read at paragraph 13.4 of the Draft Plan that the Council continues to keep the position that it will not be reviewing the Borough’s Green Belt boundaries, despite its unmet housing needs.
Paragraph 146 of the NPPF (December 2023) states that before concluding whether exceptional circumstances exist to justify changes to Green Belt boundaries, all other reasonable routes for meeting its identified need for development should be considered. Paragraph 146 states that “This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:
a)
makes as much use as possible of suitable brownfield sites and underutilised land;
b)
optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c)
has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
The findings of the Urban Capacity Study (2023) demonstrate that if the shortfall in housing need is not able to be delivered in neighbouring authorities, then exceptional circumstances will exist for a review of Green Belt boundary as per parts a) and b) of paragraph 146 of the NPPF (December 2023).
The Black Country Green Belt Study (2023) identified 12 sites across Dudley with a ‘Weak/No contribution to Green Belt purposes. Additionally, the West Midlands Combined Authority Assessment of the Potential for Additional Brownfield Land Development Capacity (2022) Report (which formed part of the evidence of the now abandoned Black Country Plan) identifies that the release of Green Belt sites across Dudley could deliver 1,117 homes.
The release of these sites would deliver the shortfall in homes needed to meet the needs of the authority’s shortfall and should be viewed in the context of a constrained housing market area where significant shortfalls in housing provision and available sites are likely to persist well into the future (see our response to Policy DLP1 – Development Strategy).

Comment

Representation ID: 1268

Received: 06/12/2024

Respondent: Stratford District Council

Policy DLP49 concerns Dudley’s Green Belt. The policy states that a strong Green Belt will be maintained. Para 13.4 clarifies that the Plan is not proposing to review any of the Borough’s Green Belt boundaries or allocate any development sites within the Green Belt in accordance with the preferred spatial strategy

Support

Representation ID: 1313

Received: 06/12/2024

Respondent: Lichfield District Council

Policy DLP49 states that DMBC has taken the decision not to review Green Belt boundaries within the Dudley Local Plan. This
follows changes which were made to the NPPF in December 2023 which allowed authorities to determine whether they
would undertake a review of the Green Belt. It is noted that following the general election in July 2024 government have
consulted upon further changes to the NPPF which could reverse the changes made in December 2023. Should these changes
come into force this would require authorities to undertake a Green Belt review should they not be able to accommodate all
their housing within their administrative boundaries, subject to any transitional arrangements.
Whilst LDC recognises that Dudley is seeking to deliver a brownfield first strategy, it is considered that DMBC should seek to
accommodate as much housing within its own administrative boundary as possible to meet its own needs, including
considering whether Green Belt release could assist in accommodating need. Given the significant scale of the unmet needs
within the HMA and FEMA it is important that potential options for accommodating need, including within the Green Belt,
are considered and fully explored. There are limited areas beyond the Green Belt within the HMA and FEMA and should all
authorities determine not to consider their Green Belt boundaries this could significantly limit the ability of the authorities to
address these shortfalls. Indeed, the delivery of homes within DMBC’s area would ensure the homes and employment are
delivered closest to where the need arises.
DMBC will therefore need to fully justify and evidence that there are no exceptional circumstances that exist that could
justify potential Green Belt release. Given the significant level of unmet need and noting the benefits of delivering need
closes to where it arises, it is Lichfield district councils view that such circumstances exist.
It should also be noted that should the revised NPPF be published, and the transitional arrangements require, then there may
be a need for DMBC to undertake further work in relation to its green belt boundaries to fully explore all options to meet is
development needs within its own administrative area. Such work may be required to ensure that the local plan is justified.

Object

Representation ID: 1333

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP49: Green Belt is considered unsound by the Home Builders Federation (HBF) for being unjustified, ineffective, and not aligned with national policy.

HBF's concerns include:

Housing Crisis: HBF highlights the ongoing housing crisis and stresses that Dudley Borough must allocate sufficient sites to meet housing requirements. This includes a mix of open market and affordable housing, with careful monitoring to ensure delivery.

Green Belt Review: HBF argues that Dudley should explore all options to meet housing needs, including a Green Belt review. They suggest that the exceptional circumstances of the housing crisis may justify releasing land from the Green Belt to address housing shortages.

Monitoring and Green Belt Release: HBF recommends that Dudley should monitor housing delivery across the wider region. However, they believe Dudley should do more to meet its own housing needs, including through Green Belt release, and that the Green Belt policy should be revised to reflect necessary changes in the Plan.

Object

Representation ID: 1349

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Do not agree with wording related to access to the countryside and open spaces for recreation. Release of Green Belt land can increase public access with new open spaces/parks and bring biodiversity net gain benefits. Agree that where Very Special Circumstances can be demonstrated planning permission should be granted, however the most appropriate way to deliver large scale new housing is through a local plan.

Comment

Representation ID: 1356

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Rep says DLP6.3 but comment doesn't appear to be related to policy DLP6 or paragraph 6.3.

CPRE welcomes the decision of Dudley MBC not to review the boundaries of its Green Belt, but we are concerned at the Borough’s inability to meet the whole of its development needs (see our objection to DLP1.1).

Comment

Representation ID: 1379

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

National Policy provides several specific cases where (exceptionally) development is permissible in the Green Belt. The policy fails to set these out. If the intention is to incorporate the policy of NPPF (which would be welcome), this should be more explicitly stated.

Comment

Representation ID: 1408

Received: 21/11/2024

Respondent: National Trust

Whilst we have not previously commented on this policy, as the Regional Park land is also designated Green Belt within Dudley, we felt it necessary to respond to the policy wording.


We consider that the 8 Hills Regional Park concept represents significant opportunity to enhance Dudley’s Green Belt policy on the basis that any designation of the regional park whereby any speculative or planned development within the regional park area would not only have to meet the multiple Green Belt tests and potentially demonstrate Very Special Circumstances, but would also have to adhere to the Green Infrastructure principles that would form the foundation of the regional park in its delivery. As set out in the comments to policy DLP51, the regional park would better enable Local Planning Authorities to hold developers to account to ensure that any residential schemes that may be brought forward are of the highest quality, exceed the minimum green infrastructure criteria and contribute to the regional park which could also ensure that new residential schemes are more cohesive when being considered in their local context. Additionally, given the layers of considerations that would be required to support development within the regional park area, this would ensure that poor quality developments are not accepted on the basis of only their contribution to
housing numbers. We are of the view that designating the regional park as part of Dudley’s
Green Infrastructure network could tangibly strengthen the Green Belt policy set out.


It is proposed that, building on the concept set out within the Spatial Framework, and the successful inclusion of the regional park within relevant Local Plans, that a regional SPD or some supporting policy could be developed to support the delivery of the regional park, which would add further detail to the expectations of any planned or speculative development within the Green Belt and regional park.


We are supportive of the policy wording in respect of the ambition to maintain the Green Belt to “provide easy access to the countryside where the landscape, visual amenity, nature conservation and outdoor sport and recreation value of the land will be protected and enhanced”.

Object

Representation ID: 1419

Received: 29/11/2024

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

It is overwhelmingly apparent, DMBC cannot feasibly or legally meet the emerging NPPF and its transitional arrangements. Therefore inevitable that a Green Belt review is required for this Local Plan. As it stands, Policy DLP49 is not justified by appropriate evidence nor has it been positively prepared.

Object

Representation ID: 1515

Received: 29/11/2024

Respondent: Feoffess of Oldswinford Hospital (Foundation)

Agent: Turley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Foundation objects to the wording of draft Policy DLP49, which states that a "strong Green Belt will be maintained" to promote redevelopment and provide access to the countryside, while protecting the land's landscape, nature conservation, and recreational value.

The Foundation argues that **exceptional circumstances exist** for Dudley Borough to consider **releasing suitable Green Belt land** to meet housing needs. Ensuring an adequate land supply, including from both brownfield and greenfield sites (such as Green Belt), is critical to addressing Dudley’s housing requirements. The Foundation calls for the plan to be more **ambitious** in tackling this issue, as identifying sufficient land will improve residents' quality of life and accommodate future generations who wish to live in Dudley.