Support

Representation ID: 985

Received: 25/11/2024

Respondent: Dennis R Whittaker

Strongly support.

Comment

Representation ID: 1182

Received: 29/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

This objection concerns the land within the Borough on the slopes of Wychbury Hill, bounded by the Borough boundary; Hagley Road, Pedmore; Pedmore Hall Lane and Pedmore Lane. The plan will be unsound unless particular protection is provided to it as an area of Great Landscape Value and a Local Green Space.

I note (and welcome) DLP35 (Geodiversity), DLP49 (Green Belt), para 13.18 (8 Hills Regional Park), DLP52 (Geology). However, in view of the likelihood that the present government will pressurise Dudley MBC to undertake a Green Belt Review, it is desirable that this plan should provide the maximum possible protection for the best landscape assets in the Borough.

It would be good if the Plan could contain an explicit policy supporting so much of 8 Hills Regional Park as is within the Borough. I appreciate that this is currently only an emerging proposal, but it is in Dudley MBC’s power explicitly to endorse the National Trust’s proposals by means of a Policy in this Plan, which will carry much more weight than mere warm words in the supporting text.

Wychbury Hill is important:
• It is a landscape feature visible for many miles.
• It is crowned by a multivallate Iron Age hillfort, of which about one-third is within the Borough.
• The other two-thirds are part of the Hagley estate and probably within the designation of Hagley Park as Grade 1 registered parkland. The designation of the rest of the hill will serve to protect the setting of the registered park
• A geological exposure is specifically mentioned as a feature of the Black Country Geopark.
• I understand that the emerging Hagley Neighbourhood Plan intends to provide some landscape designation for the land below the summit of Wychbury Hill within Hagley, so that a similar designation of the land around Pedmore Hall within the Borough would be welcome. (I am on the committee preparing the Neighbourhood Plan, but it is only at the stage of formulating proposed policies.

Attention is drawn to the report prepared for CPRE on the Landscape of the Clent and Lickey Hills. I (as chairman of CPRE Worcestershire) ensured that the area covered included the area described in the first paragraph above. A copy of the report is attached.

Object

Representation ID: 1340

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed policy seeks to secure the protection of non-designated heritage assets, to the same level as designated assets, which could comprise a wide range of landscapes or townscapes in addition to buildings and structures, in a highly restrictive manner that is not consistent with the Framework. The Framework at Paragraph 203, in respect of non-designated assets, requires that a ‘balanced judgement’ be made, having regard to the scale of any harm or loss and the significance of the heritage asset. It is considered that the policy should be amended to reflect the level of protection afforded to non-designated heritage assets through the Framework.

Object

Representation ID: 1395

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The proposed policy seeks to secure the protection of non-designated heritage assets, to the same level as designated assets, which could comprise a wide range of landscapes or townscapes in addition to buildings and structures, in a highly restrictive manner that is not consistent with the Framework. The Framework at Paragraph 203, in respect of non-designated assets, requires that a ‘balanced judgement’ be made, having regard to the scale of any harm or loss and the significance of the heritage asset. It is considered that the policy should be amended to reflect the level of protection afforded to non-designated heritage assets through the Framework.

Comment

Representation ID: 1410

Received: 21/11/2024

Respondent: National Trust

As set out above, it is considered that the designation of the Regional Park can reinforce and support this policy in respect of the enhancement opportunities that could be brought forwards for archaeological features and historic character within the Regional Park area.


We are supportive of this policy, particularly in respect of the preservation and enhancement required in “Areas of High Historic Landscape Value (AHHLV) that demonstrate concentrations of important wider landscape elements of the historic environment, such as areas of open space, woodland, watercourses, hedgerows, and archaeological features, that contribute to local character and distinctiveness” and “Archaeological Priority Areas”, both of which are found within the Regional Park area.

Object

Representation ID: 1424

Received: 29/11/2024

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

DLP55 and DLP60
Rep details information for Site at Bromwich Lane and suitability of site with these policies.

Given the nature of this designation, washing over large areas rather than site specific, the policy should be more flexible where it is demonstrated that the development would not cause significant harm to the designation and appropriate mitigation is proposed. This would allow opportunities for well-designed, sustainable development to come forward subject to other policy restrictions.

As it stands, Policies DLP55 and DLP60 are not justified or positively prepared.

Comment

Representation ID: 1501

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate previous Regulation 18 comments.

Welcome references to the canal network and cross references to Policy DLP36 Canals in Policy DLP55. Query whether separating the policy with archaeology matters addressed in a separate policy would assist with clarity.

Request cross-referencing to Policy DLP36 Canals within other historic environment policies in this chapter (within justification text).

Refer to advice on Policy DLP41 on implications of retrofitting historic buildings.

Support

Representation ID: 1561

Received: 29/11/2024

Respondent: Historic England

Section 14 Historic Environment We are supportive of such an extensive and locally responsive chapter in the Plan for the historic environment, covering both designated heritage assets as well as local designations specific to Dudley and its unique and special history and character. We particularly welcome the overarching holistic approach of the policy section which seeks to ensure that designated and non designated heritage assets are protected but also focusses on the wider local distinctiveness of Dudley and the less tangible elements of the historic environment to ensure that the uniqueness and character of Dudley is safeguarded for future generations.

The policies are well considered and are justified by significant evidence, as detailed within the Plan, which in turn will ensure that the policies are effective in practice. We welcome this approach.