Comment

Representation ID: 278

Received: 21/12/2023

Respondent: Dreadnought Developments Ltd

Agent: Mr Timothy Blairs

My client also owns the site of Dreadnought Business Park, for which further phases of development are planned. It is noted that part of the "Strategic High Quality Employment Area" allocation covers this site and also includes a small parcel of land which connects with Tansey Green Road. Due to the size and parameters of this small site, it is unlikely to be included withinany plans for an extension of the Dreadnought Business Park.

Policy DLP 21 allows for non-designated Employment Areas to be re-classified for alternative uses. However, as this parcel of land is included within a designation / allocated Employment site, there is no scope under DLP21 for any re-classificiation if this small parcel of land is left undeveloped and there is no prospect of this small piece of land being developed for Employment uses in isolation.

On behalf of my client, and with specific reference to this small parcel of land, we would request that it is either removed from the designation (pink colouring) to allow alternative more appropriate uses to be put forward, or a change in the wording of Policy DLP21 to allow such small "designated" sites to also be re-classified as per the wording of DLP21.

Object

Representation ID: 355

Received: 12/12/2023

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP21 – Other Employment Areas
4.1.
Draft Policy DLP21 establishes the Council’s proposed approach for employment areas that are not designated as either Strategic Employment Areas or Local Employment Areas but which comprise existing employment land within the Borough. Draft Policy DLP21 advises that such areas will either be retained and enhanced for industrial employment uses; or be redeveloped for housing or community, entertainment, food and drinks, or leisure uses. However, the redevelopment of ‘other employment areas’ within the Borough, will only be found acceptable under the provisions of Policy DLP21 where robust evidence has been provided to the Council to demonstrate that the site is no longer required, or viable, for industrial development. Policy DLP21 also requires that demonstration is provided to the Council to confirm that the site can be brought forward for housing in a comprehensive manner and that residential development would not adversely affect the ongoing operation of existing or proposed employment uses on the site or nearby to the site.
4.2.
The aspirations of Policy DLP21, which promotes the redevelopment of employment land that is not allocated for a specific purpose for residential and commercial / leisure development is supported in principle. However, the policy text as currently drafted by the Council fails to acknowledge that a number of existing employment sites within the Borough are already allocated for redevelopment through residential use under the adopted Local Plan, and that such allocations are proposed to be carried forward through the Dudley Local Plan review. The loss of the existing employment use of these sites, such as the land off Thorns Road, has therefore already been assessed by the Council and deemed acceptable through the site allocation process for previous adopted policy documents. In such circumstances, the principle for the loss of such employment uses is already established, and Policy DLP21 should be amended to account for this to ensure that the delivery of allocated sites is not arbitrarily constrained.
4.3.
The proposed extent of draft allocation DLP H017 would currently conflict with the approach proposed by the Council within draft Policy DLP21 whereby the proposed allocated site extent would result in an existing industrial use being enclosed by new residential development. This would not secure the comprehensive and coordinated redevelopment of this allocated site. It is therefore advised that the Council revisit Policy DLP21 and any associated site allocations which propose the redevelopment of employment land for residential use to ensure that there is consistency between these policy provisions. This is critical in order to ensure that the Plan is consistent with the provisions of national policy, in particular meeting the soundness test to be ‘effective’ as set out in Paragraph 35, and the requirement for policy to be clearly written and unambiguous, as required by Paragraph 16 to ensure that it is readily apparent how policies should be interpreted and redevelopment proposals be assessed in the decision-making process.

Support

Representation ID: 418

Received: 21/12/2023

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

1.1 Emery Planning is instructed by our client, Pegasus Grab Hire Ltd, to submit site specific representations
to the Dudley Local Plan Regulation 18 consultation. These submissions relate specifically to the land at
Bott Lane, Lye, Stourbridge (“the site”), part of which is currently used as an aggregate sorting and
recycling facility. A site location plan is provided at Appendix EP1.

1.2 This statement supports the allocation of our client’s site within the emerging Dudley Local Plan for
employment use, primarily reflecting the established and successful Pegasus Group operations.

1.3 The land at Bott Lane can continue to contribute to meeting the identified employment land needs of the
borough, within an already established industrial location. Part of the submitted site benefits from temporary planning permission for the use as an aggregate sorting and recycling facility until 2026 (ref. P20/1801) and other parts of the land within our client’s control have existing use rights for waste recycling. The remainder is currently vacant but available for expansion and diversification of the existing
facilities and businesses.

1.4 The facility has and continues to provide employment benefits and it is considered that there are no
constraints in terms of the connections to local services and infrastructure which would prevent the
continued use of the site for employment purposes. It is considered that the continued and permanent
operation of our client’s business from this site will contribute to and be complimentary to the regeneration objectives of the plan and assist with delivering wider sustainability and development objectives.

National Planning Policy Framework
2.1 The Framework sets out the Government’s planning policies for England and how these are expected to
be applied. The purpose of the planning system is to contribute to the achievement of sustainable development. The Framework, taken as a whole, constitutes the Government’s view of what sustainable
development in England means in practice for the planning system.
2.2 Paragraph 11 requires plans and decisions to apply a presumption in favour of sustainable development.
For plan-making this means that:
a) all plans should promote a sustainable pattern of development that seeks to meet the development needs of their area, align growth and infrastructure, improve the environment, mitigate climate change (including by making effective use of land in urban areas) and adapt to its effects;
b) strategic policies should, as a minimum, provide for objectively assessed needs for housing and other uses, as well as any needs that cannot be met within neighbouring areas, unless:
i. the application of policies in this Framework that protect areas or assets of particular importance provides a strong reason for restricting the overall scale, type or distribution of development in the plan area; or
ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.

2.3 Paragraph 35 provides the following in relation to soundness: 35. Local plans and spatial development strategies are examined to assess whether
they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are:
a) Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs ; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
b) Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
c) Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
d) Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in this Framework. National Planning Practice Guidance

2.4 The PPG was launched in March 2014. It replaced a number of practice guidance documents that were
deleted when the PPG was published. Local Plan making is addressed under Section 12 of the most recent
version of the PPG. The relevant sections are referred to in our representations. Dudley Local Plan – Part One

Support

Representation ID: 465

Received: 19/01/2024

Respondent: CPRE Worcestershire

WM CPRE generally supports the reallocation of employment land for housing where the land is not needed for employment use and there is a good case for doing so.

Comment

Representation ID: 523

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

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. 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. We therefore suggest the following additional wording is included to provide clarity:
"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: [...]"

Comment

Representation ID: 524

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Policy DLP22 - The wording of Draft Policy DLP22 appears to be similar to Policy DLP21. In particular, point 2 (a) and (b) of Policy DLP 21 and point 2 (a) of Policy DLP22 both discuss the requirement of industrial / employment uses and their viability. Additionally, point 2 (d) of DLP21 and point 2(b) of DLP22 has regard to avoiding adverse impacts upon. It is not clear what the need for two similar policies is, and it is our suggestion that draft policies DLP21 and DLP22 are reconsidered as a single policy, to ensure that there is no duplication which when applied could be confusing and onerous.