Object

Representation ID: 1149

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy DLPD1 and Table 2.1 seeks to identify a number of sites within the Dudley Town Centre which it suggests are appropriate for residential development. Whether or not the sites are appropriate for residential development in principle, the Policy and allocations are objected to. The sites will not deliver the scale and nature of residential development as proposed in the Policy/Allocations. Only detailed provisions are set out in respect of the Priority Sites and no similar level of detail is provided in justification for the other allocated sites listed.
There is no evidence to support and justify the sites, the scale of development or the trajectory of delivery noting clear and obvious challenges to these sites within the Policy coming forward and include (but are not limited to);
- Multiple land ownerships constraining delivery
- Timeframes, costs and issues associated with land acquisition
- Relocation of existing businesses and uses on site, including business viability to move and the availability of alternative suitable premises
- Land contamination
- Land stability and former historic uses
- Levels and the impact on development quantum.
- Accessibility and ability to connect to key services and facilities
- Access to schools and other required infrastructure
- Noise implications given adjoining uses and highway infrastructure
- Flood Risk and the application of the sequential test
- Unsuitability of service and key development infrastructure
- Absence of any evidence to show the sites can meet the policy requirement for all sites to contribute to required development infrastructure under Policy DPL6.
- Evidence to show the ability of accommodating policy requirements for sustainable drainage and BNG
- Viability generally
- Ability to accommodate other general sustainable building policy requirements viably.
- Market interest to deliver the development
- Market interest for the units to be provided
- The alignment of units to be delivered to HMA needs identified.
- Impact of panoramic view cone, strategic and local views on development potential
- Retention of protected and other trees and green infrastructure and the ability to provide gains in such, and the impact on development potential.

Comment

Representation ID: 1535

Received: 29/11/2024

Respondent: Canal and River Trust

GENERAL COMMENT ON ALLOCATIONS

Reiterate previous Regulation 18 comments.

Where not explicitly referenced in the allocation policies general reference to Policy DLP36 Canals should be included within the justification text.

Comment

Representation ID: 1579

Received: 29/11/2024

Respondent: Historic England

Table 2.1 Dudley Site Allocations

There is no reference to the HIA for these sites or any mitigation measures that may be required in order to overcome any harm as a result of allocation.