Support

Representation ID: 724

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Paragraphs 3.8 to 3.10. The PCCWM wishes to acknowledge and support the reference to
resilient and safe communities in the Forging a Future for All Vision and its reflection in the third
objective under the priority ‘Dudley the safe and healthy borough’ as part of the current
Corporate Plan, i.e. ‘Residents live in safe communities where safeguarding of vulnerable people
of all ages protects them from harm and support the prevention of crime and exploitation’.
[Support]

Comment

Representation ID: 725

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Table 3.2. While the PCCWM appreciates that it is difficult to encapsulate all of the issues in this
analysis, it is felt that the various entries in this table that relate to design quality and
infrastructure do tend to gloss over the importance of providing a secure and safe living
environment. There is no reference to policing, yet all other public services and infrastructure
providers do appear to be picked up. References might be appropriate under the following issues:
• P35 “Delivering homes of a high-quality, safe and secure design that reflect the
character and distinctiveness of the borough’ and the proposed policy, ‘Design is an
overarching concept which interacts directly or indirectly with all other aspects of the
plan. Strategic design policies in the DLP aim to form the foundations on which to build
future detail and ensure that development is located and designed to create safe and
secure places for all residents in future.’ (Suggested changes in bold and underlined).
[Objection]
• P36 “Ensuring access to local services and supporting infrastructure” and “Balancing
growth across communities by ensuring that local services and facilities continue to
thrive”, under column 3 in both entries, amend second bullet to: ‘• Liaison with health,
West Midlands Police and education providers’. (Suggested changes in bold and
underlined). [Objection]
• P37 “Health, safety, security and wellbeing of residents” under the proposed policy approach, ‘The Plan recognises the important role that spatial planning has in the
creation of healthy, safe, secure and inclusive communities and that the places that we
live in have a fundamental impact on health quality of life. Many of the policies of the
Plan will have an impact on these matters, so it is important that community needs are
supported through the provision of appropriate physical and social infrastructure and
the built and natural environment, including the public realm, allows for and supports
healthy living choices for residents everyone.’ The third column could refer to ‘Liaison
with West Midlands Police’. (Suggested changes in bold and underlined with
strikethrough). [Objection]
• P37 “Infrastructure needed to support new growth”, under column 3 in both entries,
amend second bullet to: ‘• Liaison with health, West Midlands Police and education
providers’. (Suggested changes in bold and underlined). [Objection]
The vision for Dudley Borough by 2041, P45/46:
• Amend 4th bullet to read, ‘• sustainable urban growth delivering distinctive, safe and
secure places - meeting the needs of its communities and businesses. [Objection]
• Amend 9th bullet to read, ‘• a high quality and beautiful natural, built and historic
environment and safe and secure public realm that respects and enhances local
character and distinctiveness, including valued historic buildings and areas, and
continues to be regarded as a tourist destination, and UNESCO Global Geopark with
enhanced tourism facilities’. (Suggested changes in bold and underlined). [Objection]
p48 Under Objective 3, amend 'Strategic Priority 5: Creating safe and secure well designed and
beautiful places, promoting the health and social wellbeing of communities by:’ and also, add
additional bullet on the following lines, ‘Ensure that the principles of Secured by Design are
integral to new development and improvements to the public realm’. (Suggested changes in
bold and underlined). [Objection]

Comment

Representation ID: 767

Received: 22/12/2023

Respondent: Canal and River Trust

GLOSSARY

The Trust requests the explicit inclusion of the canal network within the definition of blue infrastructure (ACTION REQUEST). A similar list of elements constituting Green Infrastructure, if introduced, should also include the canal network (ACTION REQUEST).

Support

Representation ID: 772

Received: 21/12/2023

Respondent: National Trust

The National Trust supports the Vision for Dudley Borough, particularly in respect of the objectives to have a network of high-quality parks, green spaces, waterways, and nature reserves; and a high quality and beautiful natural, built and historic environment that respects and enhances local character and distinctiveness. It is considered that both of these objectives will significantly contribute to the enhancement of wellbeing for local residents and climate change adaptation and resilience.
We are supportive of the Strategic Priorities that have been identified, and we consider that the 8 Hills Regional Park could achieve a great deal in respect of Strategic Priority 1: Addressing the Climate and Ecological Emergency, Strategic Priority 2: Protecting and enhancing the natural and historic environment and support an increase in biodiversity and ecological networks, Strategic Priority 5: Creating well designed and beautiful places, promoting the health and social wellbeing of communities by: improving access to high quality open spaces and sport and recreation facilities, to help support healthy lifestyles.
The proposed section of 8 Hills Regional Park located in the south east of Dudley Borough would connect into the wider Regional Park extending east to west from Dudley, Bromsgrove and Birmingham, in the southern area of the West Midlands conurbation where there is considerable recreation pressure on the green spaces in the area.

Comment

Representation ID: 781

Received: 22/12/2023

Respondent: Canal and River Trust

GENERAL HOUSING ALLOCATIONS

Site allocations will fall to be considered under Canal policy DLP36, where relevant, as planning applications emerge, and where not explicitly mentioned within allocation policies general reference to the application of
Policy DLP36 Canals, in decision-making should be included within justification text. (ACTION REQUEST)

Comment

Representation ID: 788

Received: 30/01/2024

Respondent: Historic England

Para 2.2-2.4. We support these paragraphs.
Para 2.28-2.29. We support these paragraphs.
Chapter 3 Page 42. Support reference to heritage tourism.
Vision. We support the reference to heritage within the vision.

Comment

Representation ID: 789

Received: 30/01/2024

Respondent: Historic England

Strategic Objectives. We would recommend a specific objective for the historic environment, rather than being included with the natural environment. The aims of the objectives are not always the same or it is not always clear how all the different elements have been considered.

Comment

Representation ID: 806

Received: 30/01/2024

Respondent: Historic England

DLP41. Historic England are supportive of a climate change policy, and we have prepared extensive material on our website relating to heritage and the climate agenda. We welcome reference to heritage within Clause 1) h. We would recommend rephrasing the policy wording relating to heritage to ensure that appropriate energy efficiency measures are utilised for heritage assets.

Comment

Representation ID: 830

Received: 30/01/2024

Respondent: Historic England

PART TWO

Part Two - We have not at this time, had the opportunity to comment on the proposed site allocations. We will seek to undergo this in the new year and will be available to discuss with the Council in a meeting to be arranged, if this is considered appropriate. We have provided a link to our advice note, above, relating to proposed site allocations and our expectation of the evidence base used to inform the process. Where any proposed allocations could harm the historic environment, heritage assets and their setting, we would expect to see a heritage impact assessment or similar evidence base and sites either ruled out of the process or any mitigation/avoidance measures incorporated in the Plan as part of site specific policies/ masterplan approaches.

Support

Representation ID: 845

Received: 19/12/2023

Respondent: Sport England

Support for vision, strategic priorities 5, 6, 7 and 8. All relate well to Sport England's Active Environments Big Issue and Active Design Guidance.

Comment

Representation ID: 861

Received: 21/12/2023

Respondent: Mr Martin Parker

I would very much appreciate the council further protecting green spaces and woodland within and surrounding the Clockfields estate from any potential future development, notably the recently designated land at Clockfield SLINC which i would like to declare my full support for as well as the green space known as 'Culverhouse Open Space'. If it is possible to allocate any greater level of protection to the land in recognition of its value as green space to the Clockfields residents and local community that would be very much appreciated as it has ben proven to have great ecological benefit for the area as part of a wildlife corridor between Corbett Meadow and the Stourbridge Canal via Coalbourne Brook. There is a strong, growing and passionate Facebook group (Clockfields Green Space Campaign) dedicated to protecting the green space and woodland on the estate and we would very much appreciate the support of Dudley Council in protecting it for future generations as was stated in the local media upon designation of the Clockfields SLINC.

The land is used recreationally by many residents as well as for educational outdoor activities by a nearby nursery. It is a peaceful, tranquil retreat from the busy Brettel Lane and the trees provide many benefits as part of the Black Country Urban Forest, for nature, drainage and air quality as well as providing visual amenity for the residents. I feel that the green space should be considered for Local Green Space designation owing to the importance and benefits of it to the local community. My concern is that at present i dont believe Dudley Council gives SLINC's absolute protection against development and feel they should be given more protection as green spaces and wildlife habitats become increasingly important in urban and suburban areas.

Object

Representation ID: 863

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

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

Support

Representation ID: 865

Received: 22/12/2023

Respondent: West Midlands Resource Technical Advisory Body (WMRTAB)

The Draft DLP includes ‘Strategic Priority 2’ which involves ‘Protecting and enhancing the natural and historic environment and support an increase in biodiversity and ecological networks by:….

• the effective and appropriate use of previously developed land and natural resources including sustainable building techniques and provides for sustainable waste management and disposal’.

WMRTAB supports the inclusion of such a strategic priority.

Comment

Representation ID: 871

Received: 22/12/2023

Respondent: Worcestershire County Council

Transport Modelling

A Black Country Plan Modelling report ‘Draft Plan 01 Assessment Technical Note’ January 2023 (ATN) has been provided as part of the transport evidence
base informing the Draft Dudley Local Plan Consultation.
In response to statutory consultation stages for the former Black Country Plan (BCP) and Brierley Hill Area Action Plan, WCC Highways requested further engagement from the plan-making authorities regarding the approach to
developing the transport evidence base and transport modelling, as WCC was
concerned that the then-emerging growth strategies may result in potential cross-boundary impacts on Worcestershire’s highway and transport network.
However, to date, further engagement with WCC Highways has not been undertaken.

WCC Highways notes from the ATN that Sweco, supported by Arcadis, were commissioned by Sandwell Metropolitan Borough Council to undertake the Black
Country Plan Modelling (BCPM) for the purposes of understanding the transport impacts of the BCP to 2039, across the Black Country and its surrounding regions, utilising the West Midlands Combined Authority (WMCA) PRISM transport model.

WCC Highways is concerned that the PRISM model network does not extend to Hagley or the northern-most extents of Worcestershire’s highway network. In particular, the model network and traffic impact analysis does not fully extend to the routes connecting Hagley to the Stourbridge, Brierley Hill and Halesowen Growth Network development locations, with the A456 Birmingham Road/Hagley Hill missing from the modelled network extent, and limited analysis of the A491
Hagley Road.

Furthermore, WCC Highways notes that the impact analysis undertaken includes some future potential highway and transport schemes across the Black Country
(although the status of these schemes remains unclear and it is noted some schemes have been ‘skipped’ due to ‘negligible impact’) as well as the full growth strategy proposed by the former BCP, which is no longer being pursued.

WCC Highways is therefore unable to identify the traffic impacts of the Draft DLP growth on Worcestershire’s transport network or the necessary infrastructure
required to support and accommodate planned development, particularly in the Growth Network development locations.

Based on the analysis provided within the ATN, it is not possible for WCC Highways to confirm if the sections of modelled network connecting Hagley to Dudley growth areas is adequately calibrated. It is noted that there are limited changes to journey times on the A491 Hagley Road and the modelled section of the A456 east of Hagley in the 2032 and 2039 do-minimum scenarios compared
to the reference case. WCC Highways would be interested to explore if these minimal journey time changes are as a result of the assumed delivery of highway and transport schemes in advance of emerging allocations being brought forward, or if they may be due to other model anomalies. In addition, WCC Highways would welcome the provision of ATN appendices, which include flow
difference plots and volume capacity ratio plots for all modelled scenarios.

As previously requested, WCC Highways would welcome further engagement with Dudley Council with the aim of exploring the approach to the development of the transport evidence base supporting the Draft Plan and to understand whether further transport modelling is proposed to underpin future plan-making stages, that is focussed on assessing the impact of planned development across Dudley and its neighbouring areas.
Should further transport evidence base development be progressed utilising the PRISM transport model, or if it is proposed to develop the Plan’s supporting transport strategy using the transport evidence presented in the ATN, WCC would welcome receipt of the Local Model Validation Report, data collection reports and any forecasting reports which may be available.

Transport: Next steps
The County Council requests that as the Dudley Local Plan is progressed, we are engaged by Dudley MBC to help determine any potential impacts on Worcestershire’s transport network and identify any necessary infrastructure improvements to be included within the Infrastructure Delivery Plan. In particular, we would welcome an early opportunity to review the PRISM transport model, Local Model Validation Report and any forecasting reports that may be available should the transport evidence base and transport strategy supporting the Dudley Local Plan continue to be progressed on the basis of the BCPM.