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Object

Part Two: Centres and Site Allocations (Regulation 19)

Representation ID: 1223

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

44. It is noted that some large employment land sites within the inner urban area are being proposed for re-development for major new housing within the council’s emerging Local Plan Review. Examples include land at Birmingham New Road, proposed for 472 new build residential dwellings. (site area 26.4
Hectares). DLP Part Two reference HO31 (site ref: CFS/SHLAA/Dev Strat) H16.1, referred to on page 212 of the DLP Part Two report (October 2024). Losing large areas of existing employment land within the inner urban area is not promoting sustainable patterns of development. The position is clear, the council’s Planning Policy Team is promoting inappropriate, damaging and unsustainable patterns of development within the local area, contrary to the “Sustainability” tests of Soundness set out under paragraph 35 (indent d) of the Revised NPPF (December 2023). The emerging Local Plan Review has also failed to consider “Reasonable alternatives” in relation to the loss of inner urban area large employment land sites. As well as failing the Sustainability test the Local Plan Review is therefore also failing Soundness tests set out under paragraph 35 (indent b) of the Revised NPPF (2023) given its continued failure to consider reasonable alternatives. The council should be releasing land from the Green Belt south of Stourbridge to help deliver thousands of new homes in order to help maintain a sufficient supply of employment land within the Dudley Borough inner urban area to help meet local community needs.

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