Comment

Representation ID: 18

Received: 10/11/2023

Respondent: Mr Alan Milway

I was pleased to see that there is an urban-led approach to the new Dudley plan and its proposed development. I do hope that this will improve the local area with a focus on regeneration and the focus is not just on adding more - sparing our greenbelt and greenfield sites which is not only vital but has been made clear to be a local issue recently. I do feel we must strike to keep and protect our greenfield sites whilst regenerating the local area where there is lots of potential for improvement on current and brownfield sites.

Support

Representation ID: 23

Received: 30/11/2023

Respondent: Susan Aston

I am pleased to see that the Kidderminster Road / Swindon Rd / Lodge Lane triangle is no longer scheduled for development.

Support

Representation ID: 24

Received: 20/11/2023

Respondent: Mr Barry Slack

Number of people: 2

Support of the Local Plan as it will hopefully maintain the two areas mentioned (Holbeach & The Triangle) as Green Belt rather than Housing. This is critical to us as we moved to Wall Heath, many years ago to be close to and surrounded by Green Belt and that is how we wish it to stay as there are far too many houses already having an effect on the schooling and medical services infrastructure.

Comment

Representation ID: 31

Received: 30/11/2023

Respondent: Mr George Morran

1. Regional Context. Can't see any consideration of the wider WM Region and its relation to Dudley MBC. For those of us who live in North Dudley this is particularly important given the proximity of development in Wombourn, South Staffs, South Shropshire as well as the rest of Black Country and Birmingham.

Comment

Representation ID: 51

Received: 11/01/2023

Respondent: P Hind

Green belt land should be protected. Some confusion between green belt and greenfield.

Comment

Representation ID: 53

Received: 11/01/2023

Respondent: P Hind

Should be brownfield first - including Moor Street near the canal.

Comment

Representation ID: 78

Received: 18/12/2023

Respondent: Mr Adrian Skelson-Reece

support the protection of the Corbett Meadow and all of the Coalbourne Brook Valley.

Comment

Representation ID: 81

Received: 18/12/2023

Respondent: Dr Christine Farmer

I am concerned that the residents of Dudley were not given a publicised opportunity during this process to submit local sites for consideration for a Local Green Space designation.

I consider that there should be a Local Green Space Designation for the “Three Fields”, Dunsley Road, Wollaston, also known as “Dunsley Fields”.

This site meets the Criteria for an LGS in both Parts A and B of the Designation, as has been shown by extensive evidence in an application which has been submitted by "Save Stourbridge Greenbelt".

Criteria Part A. The Three Fields meets all of Part A criteria for a Local Green Space, including being ‘local in character’ and is in ‘close proximity to the community it serves’ (NPPF). The site is “demonstrably special to the local community”, as evidenced by the supporting evidence submitted alongside the original LGS application. The site is extensively used by the local community, is important to residents of all ages and from all groups, regarded as a tremendous community amenity seen as adding value to the local area, important for maintaining community spirit, and an asset that should be passed on to future generations.

Criteria Part B. The site meets two of the Part B criteria (Beauty, and Recreation) and therefore meets national criteria for a Local Green Space. Beauty: The site is visually attractive, offers magnificent panoramic views, and contributes to local identity, character of the area and a sense of place. Recreational value: The site has been used for informal recreation for over 50 years, is popular with walkers, cyclists, and those using the site as a ‘green gym’. It forms part of a wider green corridor and offers walkers access to the wider countryside. It is used by dog walkers, and encourages a ‘sense of community’ amongst the socially isolated. It is very popular with children, for informal recreation, games, and nature study. The site has been used in the past for organised social activities and could be used again for similar activities as well as by local schools and community groups in activities related to the local natural environment.

In response to the argument that because a site is already Green Belt that it should not receive a LGS designation:

Government guidance on LGS designation states that even within green belts a LGS designation can “help to identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010). Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise... the community value of land” (Neighbourhood Planning, 2019, para.134). Given the ever-growing pressure exerted on local authorities to release Green Belt sites for development, a LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘green belt’. This site should therefore be granted a Local Green Space designation.

Comment

Representation ID: 88

Received: 18/12/2023

Respondent: Save Stourbridge Greenbelt

m concerned that there has been no clear procedure advertised that would have enabled local residents to submit suggestions for Local Green Spaces (LGS) during this process.

During an earlier consultation we were informed that the LGS application that had been submitted for the Three Fields was going to be rejected, despite the site meeting all necessary criteria and with enormous public support for the designation. The reason given was that the Three Fields is already designated as Green Belt.

The fact that a site is Green Belt is not sufficient protection in these times of enormous pressure on local authorities to build housing. And the policy Dudley is proposing on Green Belt only goes so far as to say they will not build on green belt "where possible" (Policy DLP49 Green Belt).

Green Belt designation itself does not recognise any additional value to the local community which a site may have above the five stated purposes of the green belt. Specifically, “green belts do not recognise… the community value of land” (Neighbourhood Planning, 2019, para.134).

Government guidance on LGS designation states that an LGS designation helps Local Authorities to "identify areas that are of particular importance to the local community” (“Open space, sports and recreation facilities, public rights of way and local green space”, HMG 2014, Para: 010).

A LGS designation would demonstrate the importance of this site to the local community and its local significance beyond that of being simply ‘Green Belt’.

For these reasons, I strongly believe that The Three Fields should be granted a Local Green Space designation.

Comment

Representation ID: 92

Received: 13/12/2023

Respondent: Mr Graham Wright

As far as I can see there are no plans to address any of these issues and one road closure in this area causes complete chaos especially at school times as the current infrastructure is no longer fit for purpose.
Unless something is done a complete breakdown is inevitable.

Comment

Representation ID: 102

Received: 19/12/2023

Respondent: Mr John Davison

Strategic P 2 add 'and achieves measurable reversal of loss of biodiversity', Strt P add 'new development that enhances the Natural World' Strateg P 5 add 'ensuring development brings exposure to nature to the people' Strat P 6 add 'and access to nature'. To Strategic Priority 9 add 'and nature'

Support

Representation ID: 104

Received: 19/12/2023

Respondent: Mr STEVE CUTLER

Strategic priority 3 regarding safegarding the green belt. As part of WallHeath As One, we have campaigned long and hard to protect the greenbelt around Wall Heath and Kingswinford, so we strongly support this stategy.

Comment

Representation ID: 152

Received: 03/01/2024

Respondent: Mr David Anscombe

believe that "The Three Fields" off Dunsley Road in Wollaston should be given extra protection as a "Local Green Space" due to its extensive use by local people for exercise and recreation close to their homes.
Its location on the edge of the built up area but offering excellent views of the surrounding countryside makes it of particular value.

Comment

Representation ID: 155

Received: 03/01/2024

Respondent: Mr Derek Lower

Number of people: 2

I am writing as part of the wider consultation process to lodge my and my wife's support to designate the Clockfields Site of Local Interest for Nature Conservation as Local Green Space.

The designation of green spaces in and around the Clockfields' estate is essential to not only preserve the areas of nature conservation but it is also a necessity for sustaining the intricate balance of the local ecosystem. These areas serve as vital habitats for a myriad of species of flora and fauna. The green spaces also offer invaluable benefits to people, young and old. In addition, these areas provide people with educational, recreational, and spiritual enrichment. Protecting these areas ensures that future generations can enjoy and learn from these irreplaceable resources.

Making the area a designated Local Green Space is an investment in nature and the local community's health and in the well-being.

Comment

Representation ID: 160

Received: 19/12/2023

Respondent: Pam Archer

I have looked at the website for the Local Plan several times but I find I can’t engage with your consultation practice because there is much too much information. In order to make comments I wanted to familiarise myself with the plan, but there are so many documents and most of them are extremely long. I have tried and tried, but now given up.

Comment

Representation ID: 164

Received: 22/12/2023

Respondent: Ms Rosalind Partridge

I believe there should be a Local Green Space (LGS) designation for the Three Fields also known as Dunsley Fields.The site fulfils the criteria for LGS because it's beauty, tranquility and recreational use.

It is close to the local community extensively used and a valuable resource for Stourbridge people from dawn to dusk for their daily exercise. In early morning and evening it is very busy with walkers and cyclists.
I frequently walk there from my house o enjoy the views and atmosphere of green space. During the Covid pandemic it provided a vital link to to nature and helped many residents to maintain our physical and mental health.

It is on a ridgeway documented as an ancient border. The position of the site holds enormous historical importance for the local community.

Comment

Representation ID: 167

Received: 22/12/2023

Respondent: Susan Morris

My same concern goes to all open spaces which are vital to the population and eyed up for housing as 'a bit of
grass' I am also concerned that my local space in Wollaston known as The Three Fields will be built on.
As far as housing goes, I think more use could be made of dilapidated buildings and factories and eg disused car
parks, as well as making the private sector rental market more accessible and secure.

I am proud to live in the Dudley Borough and my hope for its future is that it can offer a safe, healthy
and sustainable future to its residents now and for future generations.

Comment

Representation ID: 169

Received: 21/12/2023

Respondent: Dr Kevin James

I believe that the “Three Fields”, Dunsley Road, Wollaston — also known as “Dunsley Fields” — should be designated as a Local Green Space (LGS). The site, on the historically-important western edge of Dudley Borough, fulfils the criteria for a LGS designation due to its beauty, tranquillity and recreational use. It lies close to the residential areas of Wollaston, Norton, and Stourbridge's 'Old Quarter', is extensively used for recreation and dog-walking, offers almost panoramic views unmatched in the locality, and is regarded by residents as a tremendous community amenity. I would wholeheartedly support the application for a Local Green Space designation for this site, made by Dr C Farmer in 2020, and would ask that you reconsider this application, especially in light of the overwhelming public support for local green spaces expressed during the now abandoned Black Country Plan consultation in 2021.

Comment

Representation ID: 183

Received: 19/12/2023

Respondent: Miss Yvonne Hands

We in my household believe that there should be a green space designation for the "Three fields"
Dunsley road Wollaston also known as Dunsley Fields. The site is close to local community and used and loved by all in the area and of all ages of the community too. Having lived so close to this space of glorious views for many years my children and now Grandchildren need to be able to enjoy, grow and play here and also feel safe when out with their pet dog meeting ' like minded 'people out with their own pets

Comment

Representation ID: 200

Received: 19/12/2023

Respondent: Mr Eric Hand

A designated Green Space for the Three Fields Dunsley Road

Comment

Representation ID: 217

Received: 05/01/2024

Respondent: Dennis R Whittaker

(1.) Within OLP Part 1, broadly, I support Policies and paragraphs within them unless I state otherwise.
(2.) I may add additional support to Policies and/or paragraphs that I consider most important. (3.) Reserve the right to withdraw support or objections if further evidence comes to light.

Comment

Representation ID: 242

Received: 05/01/2024

Respondent: Dennis R Whittaker

~>(A.1.) Conducting this Public Consultation during November and December when most people and many businesses are preparing for Christmas, is inappropriate.
It will deter some people from participating and calls into question its validity.

~>(A.2.) The Consultation Documents are lengthy and, in effect, replace the Black Country Plan, the Dudley Borough Development Strategy and the Action Plans for Brierley Hill, Dudley, Halesowen and Stourbridge.
It is virtually impossible to assimilate and consider all of this information in one go and it would have been better to have Consulted on Part 1 first and Part 2 later.
Given inconsistencies and contradictions, I get the impression that the documents have been rushed.

Comment

Representation ID: 272

Received: 22/12/2023

Respondent: Friends of Homer Hill Park

The extended Flint Field area north of Oldnall Road, along with the site of the Oldnall settlement and Oldnall Colliery, should be protected by designation as Local Green Space.

All of the criteria for such designation is fulfilled, ie beauty, tranquility and use for recreation by the community.

It also has great historic interest as there is evidence of very significant prehistoric and Roman settlement within the site within the Flint Field site: a large quantity of Mesolithic flints; a lesser number of Neolithic flints; Bronze Age and Iron Age shards; evidence of a Romano-British farmstead (occupied 1st to 4th century).

It is an important part of our local history which should be preserved for future generations to learn about,enjoy and explore, along with the natural beauty of the entire site.

The area needs protection from re-development. Its status as greenbelt land should be added to by LGS designation.

Green belt designation does not prevent all development. It does not recognise the value of the land to the local community surrounding it, as does LGS designation.

Comment

Representation ID: 275

Received: 21/12/2023

Respondent: Heyford Developments

Agent: Harris Lamb

In light of the Council's need and the shortfall that the Council is faced with, Heyford urge the Council to first consider how it can first meet its own needs with land within its own administrative area first before looking to go cross boundary. If it is confirmed that there is no other alternative other than to look to adjoining neighbours the Council are urged to enter into constructive and productive discussions with the other HMA authorities, including South Staffordshire, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.

It is our view that the focus for addressing the shortfall in Dudley should be in Dudley first but then in the authorities closest to them such as South Staffordshire, who have a meaningful ability to address the shortfall with land available adjacent to the conurbation.

Object

Representation ID: 279

Received: 21/12/2023

Respondent: Dr Baljit Bhandal

Agent: Harris Lamb

BB is promoting land for residential development at Lapal Lane to the south of Halesowen and have previously submitted details of the site to the preparation of the Black Country Plan and previously representations to the Black Country Plan Preferred Options consultation that concluded in October 2021. These representations set out why the Council’s assessment of the site had made errors and was inconsistent. In addressing these it demonstrates that the site is deliverable and capable of delivering housing / employment to meet the needs arising in Dudley.

Object

Representation ID: 284

Received: 21/12/2023

Respondent: West Midlands Housing Association Planning Consortium (WMHAPC)

Agent: Tetlow King Planning

The Draft Local Plan fails to acknowledge the value and importance of rural exception sites in meeting housing needs, particularly when the Council has a shortfall in available development sites. The inclusion of a rural exception site policy would help bring forward housing in constrained rural areas of Dudley to meet identified local housing needs. The WMHAPC therefore strongly encourages the inclusion of a rural exception site policy in helping to meet affordable housing needs.
Paragraph 82 of the NPPF (December 2023) explains:
“In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this.”
Rural exception sites are an exception to inappropriate development within the Green Belt as set out by paragraph 154 of the NPPF (December 2023).
Housing Associations are well placed to aid in the delivery of rural exception sites and as set out within Planning Practice Guidance (Paragraph: 015 Reference ID: 67-015-20210524) the Council “may wish to consider establishing or strengthening working relationships with relevant groups including” housing associations. Bringing rural exception sites forward will assist in meeting the housing needs shortfall identified by the Draft Local Plan whilst also ensuring the housing needs of Dudley’s residents are being met.

Comment

Representation ID: 286

Received: 21/12/2023

Respondent: Redrow Homes Limited

Agent: Harris Lamb

Dudley Local Plan Preferred Options Consultation
Response by Redrow Homes Limited
Harris Lamb Planning Consultancy are instructed by Redrow Homes Limited (‘Redrow’) to submit representations to the Dudley Local Plan Preferred Options consultation. Redrow is currently promoting a site for residential development in South Staffordshire which is also in the same HMA and wish to submit comments in respect of the Dudley Plan. Whilst Redrow’s interests are not explicitly located within Dudley Borough the way the Dudley Plan is currently draft will have a number of repercussions on the delivery of housing across the wider HMA. It is within this context that Redrow’s representations are submitted and you should read our comments in this context.
A shortfall in meeting Dudley’s needs
The development strategy set out within the Dudley Local Plan is to meet the Borough’s housing needs on previously developed land within the urban area. The Standard Method housing requirement for Dudley is 11,954 dwellings however there is only currently capacity to accommodate 10,876 of these. There is, therefore, a shortfall of 1,076 dwellings which are needed but which the Council is unable to accommodate within its own administrative area. The Plan is not currently proposing to release land from the Green Belt and whilst the recently updated National Planning Policy Framework (‘the Framework’) removes the requirement to review the Green Belt, the fact that it has a shortfall in the amount of housing that is needed against which it can currently provide will mean that the shortfall of 1,076 dwellings will have to be accommodated elsewhere within the HMA in adjoining authorities if housing needs are to be met in full. Paragraph 11b) still states that strategic policies should, as a minimum, provide for the objectively assessed needs for housing and other uses, as well any needs that cannot be met within neighbouring area. South Staffordshire as one of the closest adjoining authorities with a strong functional relationship to Dudley would be one such location where additional housing could be accommodated if needed.

Redrow consider this to be an unsound approach largely on the basis that if the 1,076 dwellings have to be provided elsewhere, this will reduce the availability of any alternative capacity to meet the needs of other authorities in the HMA that have much a greater unmet need, which will effectively be competing with Dudley for this capacity, when the Council has available Green Belt land within its own administrative area that it could use but which has chosen not to release. In looking to adjoining neighbouring authorities it is highly likely that if they were to agree to accommodate any of Dudley’s needs it would have to be on Green Belt
land. Clearly, if this is the case then it should be demonstrated first that Dudley has exhausted all sources of potential land within its administrative area first, including Green Belt land, before looking cross boundary. If there is no alternative then Dudley will need to work with adjoining authorities and agree with them to meet its needs. South Staffordshire, due to its close functional relationship with Dudley would be an ideal location for where new housing could be provided that would help meet Dudley’s needs.
A significant wider unmet need exists
The shortfall of land for housing is not unique to Dudley and is a long-established concern within the HMA.
Birmingham Development Plan
The Birmingham Development Plan (“BDP”) was adopted in January 2017. Policy PG1 – Overall Levels of Growth, advised that 89,000 dwellings are required during the course of the plan period (2011 to 2031) to meet the growth requirements of the City. However, only 51,100 additional dwellings can be accommodated within the City’s administrative area. This leaves a shortfall of 37,900 homes including 14,400 affordable homes (that will need to be delivered elsewhere within the Greater Birmingham Housing Market Area). The BDP stipulated that Birmingham’s unmet need was to be met by other authorities in the HMA as and when they produced individual Local Plans. This has not happened.
Birmingham City Council has now commenced a review of its Local Plan and consulted on Issues and Options for a draft Plan concluding in December 2022. The Issues and Options document advised that the Standard Method housing requirement for the period 2020 to 2042 is 149,286 dwellings. The Issues and Options consultation document suggests that the total capacity for development within the built up area of the City is 70,871 dwellings. This relies upon all SHLAA sites coming forward for development and the provision of a significant number of windfalls (the windfall sum is 11,675 dwellings). This would result in a housing shortfall in the City of 78,415 dwellings.
Black Country Core Strategy Review
Previously, the four Black Country authorities had been preparing a Joint Plan although this has now subsequently been abandoned in favour of the preparation of individual Plans for each authority. Notwithstanding the above, the Preferred Options Black Country Plan proposed a housing requirement based upon the Standard Method which was the sum of the four individual authority housing requirements. The housing requirement for the four authorities was 76,076 dwellings, however, there was only an identified capacity of 47,837 dwellings leaving a shortfall of 28,239 dwellings to be directed to other authorities. Now, each authority will calculate its own housing requirement using the standard method calculation. The requirement in Sandwell is 29,773 dwellings, however, Sandwell claim only to have capacity to deliver approximately 11,167 leaving a shortfall of 18,606 dwellings. The positions in Wolverhampton and Walsall have not yet been published although it is anticipated that there will be a further shortfall in what is required against the capacity within these two authorities.

Overall Shortfall
If the housing shortfall figure identified in Policy PG1 of the BDP and the emerging shortfalls in both the Dudley and Sandwell Preferred Options are added together it totals 57,582 dwellings. If the shortfall arising in Dudley and Sandwell is added to the emerging shortfall identified in the Birmingham Issues and Options this increases to 98,097 dwellings. As noted above, this has the potential to increase even further when any shortfall arising in Wolverhampton and Walsall is added. This is a substantial number of homes and represents a substantial number of people and families that will go without homes should a definitive solution not be found.
Where will the housing shortfall arising from Dudley be met
Paragraph 24 of the Framework confirms that Local Planning Authorities are under a duty to cooperate with each other on strategic matters that cross administrative boundaries. Paragraph 26 goes on to state that joint working should help to determine where additional infrastructure is necessary and where development needs that cannot be met wholly within a particular area could be met elsewhere. The level of unmet need arising within the HMA is one such area where the Duty to Cooperate should be employed in order to determine where this unmet need should be directed.
Having regard to the Greater Birmingham Housing Market Area there are 14 authorities within it which include Birmingham, the four Black Country authorities and 9 other surrounding authorities. In light of the shortfall arising in Birmingham, Dudley and Sandwell this effectively leaves 11 remaining authorities where the need could be distributed.
Turning to each of the remaining authorities it is highlighted above that there is potentially a shortfall that will arise in both Wolverhampton and Walsall when they come to publish their Preferred Options Local Plan. Redditch Borough is effectively built up to its boundary and already has to look to its adjoining neighbour, Bromsgrove, in order to accommodate its housing need. It would be unable to accommodate any further unmet. Similarly, Tamworth had to look to its adjoining neighbours of Lichfield and North Warwickshire in order to meet its current housing requirement in its adopted Local Plan. It too would be unlikely to be able to accommodate any unmet need arising. Cannock Chase’s capacity is restricted due to environmental constraints including the Cannock Chase’s SAC and AONB. A small part of Stratford-upon-Avon District falls within the Housing Market Area whilst North Warwickshire have previously committed to delivering 3,790 dwellings to meeting Birmingham’s needs up to 2031 in its adopted Local Plan (2021). Solihull’s Local Plan is currently at examination and is on hold awaiting publication of the updated Framework and currently proposes approximately 2,000 dwellings to meet the needs of Birmingham. If the Plan progress towards adoption in its current form there would be no scope to seek any increase in the size of the contribution from Solihull until such time as they commenced a further review.
This effectively leaves Lichfield, South Staffordshire and Bromsgrove as the three remaining authorities that would be able to make any meaningful contribution to meeting housing needs arising in the wider HMA. However, a review of what these local authorities has been proposing to help meet the housing shortfall across the HMA falls woefully short of what is needed.
South Staffordshire have previously proposed to accommodate 4,000 dwellings to meet the needs arising in the Black Country. Lichfield were proposing around 2,000 homes before withdrawing their plan. Bromsgrove has yet to publish a draft plan and so it is yet to state how many dwellings it may be prepared to accommodate. Collectively this equates to less than 12,000 (plus the homes that Bromsgrove may provide) and on the face of it will fall woefully short of addressing the housing need of local people and families across the HMA.

The outcome of the above is that there is a significant unmet housing need arising principally from Birmingham and Sandwell, with Walsall and Wolverhampton likely to add to this, and at the current time there is no agreement or clear strategy between the 14 HMA authorities as to where or how this unmet need is to be met. Furthermore, in the few authorities that have the ability to assist in meeting the overspill, with land available around the conurbation to assist with meeting the housing overspill no agreement has yet been reached with them.
It is clear from the above that the emerging position across the HMA is one where there is a significant housing need that exists, but where certain authorities, such as Sandwell and Birmingham and to a lesser extent Dudley, cannot currently meet its needs in full. Redrow contend that these needs must be met by the HMA authorities in the next round of plans that are now being prepared. If this need is not met in full, it risks giving rise to a number of significant knock on effects on the delivery and provision of housing across the Greater Birmingham area. These impacts include:
•
worsening affordability as demand outstrips supply,
•
worsening delivery and provision of affordable housing,
•
increased homelessness
•
Worsening overcrowding and living conditions,
•
Increased pressure on private rental sector with associated issues of unsecure tenancies and susceptibility to rent increases,
•
Increasing ageing population with resultant increase in demand on social and health care services,
•
economic impacts on the working age population as those adults who are able to work may not have suitable accommodation to live in thus resulting in increased commuting distances, worsening impacts on congestion and air quality, and
•
the inability to attract workers into the HMA could have significant repercussions for the wider economy if the right type of houses are not available for those wanting to live and work in the conurbation.
Next Steps
In light of the Council's need and the shortfall that the Council is faced with, Redrow urge the Council to first consider how it can first meet its own needs with land within its own administrative area first before looking to go cross boundary. If it is confirmed that there is no other alternative other than to look to adjoining neighbours the Council are urged to enter into constructive and productive discussions with the other HMA authorities, including South Staffordshire, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.
It is our view that the focus for addressing the shortfall in Dudley should be in Dudley first but then in the authorities closest to them such as South Staffordshire, who have a meaningful ability to address the shortfall with land available adjacent to the conurbation.
We trust you take our comments into consideration and we look forward to being notified of further stages of consultation on the Local Plan. If you have any questions or need to discuss please do not hesitate to contact me.

Object

Representation ID: 287

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

DMBC’s refusal to consider the release of land from the Green Belt for development to meet the housing needs of the Borough is extremely concerning. That results in a DLP that fails each of the tests as set out in NPPF Paragraph 35. It is not positively prepared, is not justified, is not effective, and is not consistent with national policy. That is, the DLP is fundamentally unsound in NPPF terms. In the context of the significant unmet needs that would otherwise arise, there are clearly exceptional circumstances to justify the release of Green Belt land, and DMBC should therefore undertake a pragmatic review of the Green Belt boundaries in the Borough e.g. Bromwich Lane, Pedmore.

Object

Representation ID: 290

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

The proposed 2041 end date is predicated on DMBC’s expectation as per the July 2023 Local Development Scheme (LDS) that the CLP will be adopted in Spring 2026. However, the timescales as set out in the LDS are extremely challenging, and itself recognises that the timely adoption is dependent on the timescales for the DLP’s examination. Given the scale and complexity of the DLP, which is effectively considering a range of matters that are currently covered by three tiers of adopted plans (the Black Country Core Strategy, Dudley Development Strategy and individual Area Action Plans), it is more likely that the plan will be adopted in late 2027 / 4 2028. To meet the requirements of NPPF paragraph 22, the plan period should therefore be extended to 2043, and the approach taken in strategic policies should be reviewed on that basis, most notably by increasing the housing requirement and identifying additional development sites.

Object

Representation ID: 299

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Housing Allocations.

The policies do not provide a concept plan or alike that would suggest where built development may be located or how the suggested capacities could be achieved. Rather, allocation capacity figures appear to be derived from the Strategic Housing Land Availability Assessment (SHLAA), which itself merely applies crude blanket assumptions based on the site area and an assumed density.