Comment

Representation ID: 79

Received: 18/12/2023

Respondent: Dr Christine Farmer

I support the policy to maintain a strong Green Belt to promote redevelopment and regeneration within the urban area.

Comment

Representation ID: 87

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

support the policy to maintain a strong Green Belt to promote redevelopment and regeneration within the urban area.

Comment

Representation ID: 150

Received: 03/01/2024

Respondent: Mr David Anscombe

fully in support of protection of the Green Belt as this was intended to prevent encroachment of urban areas into the countryside and ensure that appropriate protection is provided for open countryside around built-up areas.
This should also encourage any development to take place within existing urban areas rather than resulting in further loss of agricultural land and open countryside.
Particular attention should be given to the protection of "The Three Fields" and the "Horse Fields" in Wollaston as these provide a well-used and vital resource for local people to access fresh air and exercise close to their homes.

Comment

Representation ID: 163

Received: 22/12/2023

Respondent: Ms Rosalind Partridge

I support the policy to maintain a strong Green Belt which will promote future regeneration and development of the urban area. I am concerned about the area along the ridge in Stourbridge, particularly the Three Fields open space.

Support

Representation ID: 175

Received: 29/12/2023

Respondent: Suzanne Webb

I am delighted to see that no Green Belt sites have been proposed for development in the Stourbridge Parliamentary constituency. As this policy correctly states, the NPPF and supporting national guidance attach great importance to the Green Belt. We must prevent urban sprawl, which has been so prevalent in areas of the West Midlands, by keeping this precious land permanently open. I have always believed very strongly in building on brownfield sites before any Green Belt site can be considered. I commend the work done by DMC and the WMCA on identifying brownfield sites across the region. Much-needed homes should be focussed in these areas, leaving our Green Belt to be enjoyed by residents - as it has for generations before. Our industrial heritage means that a bounty of brownfield land remains, and it is good to see that the Local Plan has identified much of this for residential and commercial development. Not only does this preserve existing Green Belt sites, but it also regenerates and invigorates areas that have often been left to decay or have at the very least been grossly underused.

Comment

Representation ID: 199

Received: 19/12/2023

Respondent: Mr Eric Hand

I support the policy to maintain a strong green belt.

Object

Representation ID: 253

Received: 28/12/2023

Respondent: Mr Chris Horn

I am becoming increasingly frustrated by the lack of new 2 bedroom private market sale homes in the Dudley Borough, particularly in the Stourbridge, Norton, Pedmore, Wollaston area
I fail to believe how the local plan addresses this issue as there are no sites allocated for development in these areas for first-time buyers, and families.
These isnt any brownfield in these areas so where do you expect people to live and live local to get their children to school.?
Unortunately, there has to be a realistic approach, and yes, greenbelt should be built on to supply new homes in the stourbridge and surrounding areas

Support

Representation ID: 271

Received: 22/12/2023

Respondent: Friends of Homer Hill Park

I agree with and support the policy of keeping a green belt to benefit urban areas in their present state and future development.

The greenbelt surrounding Oldnall Road in Cradley & Wollescote is particularly important to our local residents for their health and wellbeing.

This was evidenced in the support given in 2020 to The Friends of Homer Hill Park & Cradley Then & Now when asking for signatures (approx 356 were obtained in a relatively short time) in favour of the green belt being kept as it is and not diminished.

A real reason for concern is the desire and of local landowners to sell what they own with no consideration of the outcome to the local population. Redevelopment for housing or commercial reasons would have devastating consequences to the nature of the area. It is also becoming obvious that politicians, namely Labour Party leaders, are openly saying that development for housing should not be held back because of considerations over loss of green belt land.

Comment

Representation ID: 283

Received: 21/12/2023

Respondent: West Midlands Housing Association Planning Consortium (WMHAPC)

Agent: Tetlow King Planning

Supporting text to draft Policy DLP49 at paragraph 13.3 of the Draft Plan is clear that “The Plan is not proposing to review any of the borough's Green Belt boundaries or allocate any development sites or proposals within the Green Belt in accordance with the preferred spatial strategy.”
In considering the evidence base which has helped inform Policy DLP49, the Urban Capacity Study (2023) states:
“Taking account of DtC, recent NPPF consultation proposals and the evidence presented in this report, the housing shortfall is not considered significant and development growth is focused in the urban area.
Currently, para 136 of the NPPF states that – “Once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.” Given the urban capacity evidence summarised in this report, it is reasonable to conclude that exceptional circumstances have not triggered the need for a Green Belt review in the Dudley Borough.”
While the findings of the Urban Capacity Study are acknowledged, it appears that over 1,000 households across Dudley will fail to have their housing needs met over the plan period if the Council does not identify further development sites or come to agreements with neighbouring authorities (see our response to Policy DLP1 – Development Strategy).
Paragraph 146 of the NPPF (December 2023) states that before concluding whether exceptional circumstances exist to justify changes to Green Belt boundaries, all other reasonable routes for meeting its identified need for development should be considered. Paragraph 146 states that “This will be assessed through the examination of its strategic policies, which will take into account the preceding paragraph, and whether the strategy:
a)makes as much use as possible of suitable brownfield sites and underutilised land;
b)optimises the density of development in line with the policies in chapter 11 of this Framework, including whether policies promote a significant uplift in minimum density standards in town and city centres and other locations well served by public transport; and
c)
has been informed by discussions with neighbouring authorities about whether they could accommodate some of the identified need for development, as demonstrated through the statement of common ground.”
The findings of the Urban Capacity Study (2023) demonstrate that if the shortfall in housing need is not able to be delivered in neighbouring authorities, then exceptional circumstances will exist for a review of Green Belt boundary as per parts a) and b) of paragraph 146 of the NPPF (December 2023).
The Black Country Green Belt Study (2023) identified 12 sites across Dudley with a ‘Weak/No contribution to Green Belt purposes’. Additionally, the West Midlands Combined Authority Assessment of the Potential for Additional Brownfield Land Development Capacity (2022) Report (which formed part of the evidence of the now abandoned Black Country Plan) identifies that the release of Green Belt sites across Dudley could deliver 1,117 homes.
The release of these sites would deliver the shortfall in homes needed to meet the needs of the authority’s shortfall and should be viewed in the context of a constrained housing market area where significant shortfalls in housing provision and available sites are likely to persist well into the future (see our response to Policy DLP1 – Development Strategy).

Object

Representation ID: 296

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

It is clear that there are ‘exceptional circumstances’ present to justify the release of Green Belt land for development in accordance with NPPF paragraph 141. That is, the emerging DLP and previous local plans have clearly maximised the potential of “suitable brownfield sites and underutilised land” and sought to optimise the density of development within such sites as per NPPF paragraphs 141a and 141b. Furthermore, it is clear that surrounding local authorities could not meet Dudley’s unmet housing needs within their own jurisdiction given that all surrounding authorities are constrained by Green Belt and, in the case of most authorities, are likely to be unable to meet their own housing needs as a result. In that regard, even by pursuing the approaches proposed in NPPF paragraph 141 (clauses a to c), a substantial shortfall in housing supply will still persist across the plan period.

The DLP continues to rely on the 2019 Black Country Green Belt Study (BCGBS) and the associated Landscape Sensitivity Assessment (BCLSA) despite WDH having highlighted multiple times that the reports are underpinned by significant methodological flaws and therefore that a number of promoted sites in the Green Belt have previously been rejected based on flawed justification. WDH’s concerns in that regard are reiterated in response to Policy DLP10.
The conclusions of the BCGBS’s Stage 1 assessment of Parcel B60 are wildly inaccurate as they have been directly informed by an unsuitable methodology that sought to assess a very large and varied Green Belt parcel, rather than breaking the parcel down into smaller parcels that more accurately reflect the clear variations in character and Green Belt contribution, as demonstrated in an appeal in St Albans.

Object

Representation ID: 333

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

1.92 Concerns are expressed elsewhere in these representations with the way the spatial strategy (Policy DLP1) of the Dudley Local Plan (DLP) is framed, the extent to which at the outset it properly acknowledges the scale and character of development need, the ways it suggests the need can be met, and the requirement to identify additional development land for housing including through Green Belt release. Those concerns are expanded in some detail in terms of policy around housing delivery (Policy DLP10), again making the point that additional development land is needed including through Green Belt release.
1.93 Those concerns have consequential effects throughout the DLP which should be accommodated. Those effects are notable in relation to Policy DLP49. The Green Belt should be assessed and reviewed such that the most suitable sites for development can be identified and allocated, and development needs can be met, in circumstances where the current excessive focus on urban cramming is inadequate and will not succeed. Persimmon Homes have promoted land at Holbeache Lane for residential development including its removal from the Green Belt to provide a deliverable site to meet housing needs. IT was removed from the Green Belt and allocated for housing in the previous draft review of the Black Country Plan – its merits for removal from the Green Belt and allocation for housing remain to this day. The attached Vision Document sets out the merits of the site and justifies its removal from the Green Belt and allocation for housing.

Comment

Representation ID: 336

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

We do not agree with the wording of this policy entirely. The presence of Green Belt does NOT automatically afford people ‘access’ to the countryside unless there are rights of way through it. Nor does it provide open spaces for recreation without formal access.

Indeed, the release of Green Belt for development can actually result in an increased level of public access through the provision of new open spaces and parks within a development, offsetting the loss of openness. We consider Policy DLP49 needs to be re-worded.

Support

Representation ID: 345

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

Save Stourbridge Greenbelt supports this policy to "maintain a strong Green Belt to promote redevelopment and regeneration within the urban area.”

Comment

Representation ID: 412

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF notes that we are in the midst of a Housing Crisis. Housing delivery is therefore a key challenge facing Dudley Borough. To address the housing crisis the Council needs to allocate enough sites to meet the housing requirement and provide choice and flexibility in supply. This will require the allocation of a mix and range of sites in a variety of locations. The policies in the Plan with then near careful monitoring to ensure they are delivering the housing. The Dudley Local Plan must ensure the delivery of new housing to meet both open market and affordable housing needs.

The issue of housing is critically important and needs urgently addressing through the plan-making process. HBF believes that the Council needs to explore any and all options to meet the housing need and requirement of Dudley. This must include full consideration of the current Housing Crisis and if it results in the ‘exceptional circumstances’ that would require the need for a Green Belt review. A plan that does not meet the area’s housing needs in full is simply not good enough and does represent an effective use of the plan-led system.
There remains a need to address issues that are wider-than-local matters in a joined-up manner under the Duty to Cooperate. The HBF notes that Dudley was closely involved in the production of the Black Country Plan (BCP), alongside the other three Black Country councils, but that work on the joint BCP officially ceased in October 2022
The HBF notes that the BCP website says “it is with regret that we are unable to reach agreement on the approach to planning for future development needs within the framework of the Black Country Plan”. The statement on the website continues that “Local Plans for the four Black Country Councils will now provide the framework for the long-term planning of the Black Country. The Black Country Plan 2039 work programme will end, and we will now transition to a process focused on Local Plans. The issues of housing and employment land need will now be addressed through individual Local Plans for each of the authorities. The Councils will co-operate with each other and with other key bodies as they prepare their Local Plans."

This suggests compliance with the Duty to Cooperate may be a key challenge for meeting the legal requirements of plan-making in Dudley, as well as policy issue. This issue has gained in importance now the NPPF revision seek to ensure housing need is meet where it originated wherever possible.

HBF suggest that there is a need for housing monitoring to be undertaken across the wider region. If other areas are providing housing to meet Dudley’s need, Dudley will need to be monitoring this delivery to ensure its needs are being met. However, HBF firmly believe Dudley should be doing more to address its own needs, including Green Belt release.

Support

Representation ID: 483

Received: 19/01/2024

Respondent: CPRE Worcestershire

WM CPRE strongly supports the protection of Dudley’s Green Belt. In line with our comments on Policies DLP1, 10 and 18 we do not consider there is any justification for releasing Green Belt in Dudley or for seeking Green Belt releases in adjoining districts to meet development needs in Dudley.

Our view on this is strengthened by the provisions of the new NPPF, published in the final days of this consultation.

Comment

Representation ID: 518

Received: 18/12/2023

Respondent: Lichfield District Council

Green Belt
In addition to the above, the draft plan states that DMBC are not proposing to review its Green Belt boundaries or allocate any development sites or proposals within the Green Belt at this stage. The rationale for this is set out within draft Policy DLP49 Green Belt.
As you will be aware, the NPPF enables local authorities to consider changes to their Green Belt boundaries through their plan-making processes. Given the significant scale of the unmet needs within the HMA and FEMA it is important that potential options for accommodating need, including within the Green Belt, are considered and explored. There are limited areas beyond the Green Belt within the HMA and FEMA and should all authorities determine not to consider their Green Belt boundaries this could significantly limit the ability of the authorities to address these shortfalls.
Given Dudley’s links to the HMA, particularly the Black Country Authorities, who had previously identified a significant shortfall of 28,239 homes, Lichfield District Council would like to stress the importance of authorities proactively exploring all options to meet need within their administrative boundaries including potential sites from all sources, including the consideration of Green Belt release, where appropriate and evidenced to ensure growth is delivered closest to where need arises.

Comment

Representation ID: 627

Received: 05/01/2024

Respondent: South Warwickshire Council

The Plan does not propose a change to Green Belt boundaries. As the shortfall in Dudley’s identified housing and employment need could have been accommodated with a fairly moderate release of Green Belt land, it is disappointing that the rationale and evidence for this decision has not been made clearer. The Council is encouraged to include the rationale in the Plan so that readers can understand whether all reasonable options have been fully explored, and whether the decision not to release Green Belt land is justified. This is of particular relevance to other Councils within the Housing Market Area. The West Midlands Green Belt is extensive, and parts of it fall within the bounds of other HMA members’ areas. Dudley Council’s decision could therefore have an unintended consequence – by protecting their own Green Belt, Dudley may simply be exporting the harm to elsewhere in the Green Belt.

Object

Representation ID: 848

Received: 31/01/2024

Respondent: St Modwen Homes

Agent: Planning Prospects Ltd

Concerns are expressed elsewhere in these representations with the way the spatial strategy (Policy DLP1) of the Dudley Local Plan (DLP) is framed, the extent to which at the outset it properly acknowledges the scale and character of development need, the ways it suggests the need can be met, and the requirement to identify additional development land for housing including through Green Belt release. At this (Regulation 18) stage the Council have failed to grapple with this and the exceptional circumstances that might exist to support a change, or to formulate a realistic alternative to meet development needs. Those concerns are expanded in some detail in terms of policy around housing delivery (Policy DLP10), again making the point that additional development land is needed including through Green Belt release.

Those concerns have consequential effects throughout the DLP which should be accommodated. Those effects are notable in relation to Policy DLP49. The Green Belt should be assessed and reviewed such that the most suitable sites for development can be identified and allocated, and development needs can be met, in circumstances where the current excessive focus on urban cramming is inadequate and will not succeed. This should be reflected in an amended Policy DLP49 and supporting text.