Object

Representation ID: 1336

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP83: Access for All is considered unsound by the Home Builders Federation (HBF) as it is unjustified, ineffective, and not in line with national policy.

Key concerns:

SPDs in Local Plan Policy: HBF supports the need for accessible environments but argues that Criteria 2 seeks to give SPD status to Local Plan policy, which is inappropriate and goes against national guidance. Planning policies should be made through the Local Plan process with public consultation and independent scrutiny during examination.

Need for Delivery, Monitoring, and Implementation:

HBF advocates for a monitoring framework within the Plan, allowing it to respond to changing circumstances. HBF opposes policies that only trigger a review if housing delivery falls short, arguing they are ineffective in addressing the housing crisis.
Action on Housing Under-Delivery: HBF suggests incorporating measures to address under-delivery more quickly than a full plan review, such as bringing forward reserve sites or making explicit reference to earlier delivery if under-performance is observed.
Housing Requirement and Needs: HBF stresses the importance of the housing requirement reflecting the Borough's needs and growth aspirations, rather than being constrained by capacity limits. This should be addressed before considering how much housing the borough can realistically accommodate.

Monitoring and Regional Coordination: HBF recommends the inclusion of a monitoring framework at the end of the Plan, ensuring that Dudley addresses its housing needs and actively participates in monitoring unmet housing needs from neighboring authorities.

Comment

Representation ID: 1565

Received: 29/11/2024

Respondent: Historic England

Policy DLP83 Clause 4

This policy should relate to the significance of heritage assets.