Comment

Representation ID: 105

Received: 19/12/2023

Respondent: Mr John Davison

Pensnett to Kingswinford. I suggest commit to bringing the mothballed railway into use for freight and passenger.

Also Brierley Hill to Stourbridge Junction railway is periodically promised as to be revived to passenger use. This should be acknowledged and supported

Comment

Representation ID: 297

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

WDH does not object in principle to the delivery of brownfield sites, but highlights in response to Policy DLP10 that the identified sites are unlikely to deliver the level of growth suggested in the policy. Therefore WDH are of the view that DMBC must identify additional allocation sites, including those located in the Green Belt, without delay.

Support

Representation ID: 306

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 2 Growth Network : Regeneration Corridors and Centres
Barberry generally welcomed the strategic approach for the growth network including the focus on development within existing urban areas and regeneration corridors. In respect of the regeneration corridors, we note that regeneration Corridor 1 Pensnett Kingswinford has a strong strategic employment area and a network of busy local centres. Furthermore, the corridor has hosted residential development on former employment areas previously and has the potential to increase investment in the Pensnett Estate. A potential opportunity at Ketley Quarry is identified as a priority site. In respect of the vision to 2041 we agree that the corridor has the potential to provide high quality residential areas with access to recreational areas, transport network, key services and centres along with employment opportunities. Directing further development to regeneration corridor would help with delivering the overall vision for the Local Plan.

Support

Representation ID: 352

Received: 12/12/2023

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP2 – Growth Network
2.8.
This draft Policy sets out the Growth Network for the Borough, which it provides is intended to the be the primary focus for new development, regeneration, and infrastructure investment to support the delivery of significant growth and promote wider benefits to communities. Section 3 of the draft Policy confirms that Regeneration Corridors will provide a minimum of 4,948 new homes in sustainable locations.
2.9.
The proposed Growth Network approach is supported, as this seeks to direct development to the most sustainable locations in the Borough, following on from the approach set out in adopted Policy including the Black Country Core Strategy and Dudley Borough Development Plan. The vision for Regeneration Corridor 3: Stourbridge to Lye, within which high quality residential communities with access to parks, employment opportunities, and high-quality transport links is strongly supported.
2.10.
The allocation of the land off Thorns Road for residential development under allocation reference DLP H017 is strongly supported, in recognition of the highly sustainable location occupied by the site. It is considered that the development of the land off Thorns Road will contribute strongly towards the realisation of the Council’s vision for Regeneration Corridor 3, by virtue of the site’s close proximity to public open spaces including Stevens Park – Quarry Bank; employment opportunities
located at the Bott Lane industrial estate to the south; and local services and amenities; all of which are easily accessible by sustainable modes of transport.
2.11.
Whilst the broad approach to growth outlined by Policy DLP2 is supported, it is critical that the Council ensure that the most effective use of previously developed and sustainable sites within Regeneration Corridor 3 is made, to ensure that such sites are able to contribute positively towards meeting the housing needs of the Borough. As identified in the response to Policy DLP1 above, the extent of land allocated under proposed allocation DLP H017 has been reduced from that which currently benefits from allocation under site allocation H13.17 of the adopted Local Plan. Justification for the proposed reduction in the allocated site extent has not been provided by the Council, and it remains the intention of Harworth Group to bring the entire extent of land currently allocated under adopted Local Plan allocation DLP H13.17 forward for residential development. It is advised that the Council amend the extent of proposed allocation DLP H017 to ensure that the redevelopment opportunity presented at land off Thorns Road can be realised in full.

Object

Representation ID: 370

Received: 21/12/2023

Respondent: Cllr Parmjit Sahota

wish to express deep concern on the amendments to the Regeneration Corridor 13 that was integral part of the regeneration corridor that ran from Jewellery Line - Rowley Regis / Halesowen border to Lye and then Stourbridge. I note the Eastern Section ( as outlined in page 109 of the DMBC Borough Strategy 2017 – attached photo) has been totally taken out.

Importantly Regeneration Corridor 14 – also covering Halesowen , Coombswood to Halesowen (page 115 of the DMBC Borough Strategy 2017 -attached photo) has been totally omitted from the new DLP. Yet other Regeneration Corridors within the borough have been carrying forward from the Borough Strategy and the BCCS documents into the draft DLP, thus extremely disappointed the downscaling / omission of these two corridors that previously were in place to support regeneration plans for Halesowen.

In the previous Black Country Plan, the Regeneration Corridor 13 - Jewellery Line- Rowley Regis to Stourbridge Junction was an integral part of the regeneration corridor that ran through the Sandwell and Dudley area. The rail line in parts forms the boundary of Halesowen. The rail line although termed Rowley Regis also straddles the border of areas of Northern Halesowen.

As Rowley Regis Station is literally yards from the Halesowen Town boundary. The Regeneration Corridor and the strategic rail has been instrumental in helping secure investment of new two hundred plus homes and large investment of business units in this northern part of Halesowen, off Cakemore Rd and Nimmings Rd and attract funding from WMCA to support aspects of the regeneration. There is further potential to deliver regeneration along Nimmings Rd to help transform low value units into new investments and open up council owned land for better utilisation. I have a site visit arranged with Mark Clarke and Paul Mountford to discuss this further Regeneration Corridor 14 – Coombswood to Halesowen - Omitted in DLP Halesowen plays a key economic role as it is home to one of only three strategic high quality employment areas in the boroughs economic map. This large area includes manufacturing businesses and is sandwiched between Coombs Rd and Mucklow Hill. Rowley Regis Train Station that sits right on the border of Halesowen Town links the town via trains to London and beyond. Halesowen also strategically is two miles from of both junction 2 and 3 of M5 and shares a border with the second City Birmingham, which acts as a Gateway for visitors from the second city in our borough .

Yet the revised Regeneration Corridor exercise undertaken by DMBC officers totally excludes the strategic location of Halesowen as an integral part of the revised Regeneration Corridors that was in existence as it was when it was in the Black Country Core Strategy Plan, see attached map. I
hope This oversight can be revisited as Halesowen Town should be benefiting from regeneration corridor status to secure funding streams to further unlock its potential as a key economic town of the borough.

There is a DMBC officer working group looking at how to finally address the neglect of Shell Corner Local Centre that has had two commissioned reports completed by DMBC highlighting the need to enhance the centre and yet nothing has yet come from these two commissioned studies??

The centre is along proposed regeneration corridor from the train station to Mucklow Hill. Mucklow Hill is seen as a key gateway to the industrial heart of Halesowen and the town centre. A number of low value sites along Nimmings Rd could be CPO owed and brought forward for regeneration and help unlock large area of council land that could be to put to better use as a residential village
for senior citizens.

Comment

Representation ID: 393

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF does not comment on individual sites or allocations, other than to say the Plan should provide for a wide range of deliverable and developable sites across the area in order to provide competition and choice to ensure that housing needs are met in full. HBF would wish to see the Plan set out a logical settlement hierarchy which meets all the housing needs and addresses all areas of the housing market, with a range of sites proposed for allocation. The soundness of strategic and non-strategic site allocations, whether brownfield or greenfield, will be tested in due course at the Local Plan Examination.

Object

Representation ID: 420

Received: 21/12/2023

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Policy DLP2 Growth Network: Regeneration Corridors and Centres

3.3 The regeneration corridors identified under Policy DLP2 will accommodate strategic and local employment
areas and the principal location for new industrial and logistics development as well as the new homes
required within the borough over the plan period.

3.4 Table 5.3 provides a summary of the opportunities and vision for each of the proposed regeneration
corridors. Our client’s land interests are located within RC3 Stourbridge to Lye. The vision for RC3 refers
to the design code and masterplan which is currently being prepared by the council and which we have
engaged with on behalf of our client as it has evolved.

3.5 As currently prepared it is considered that the regeneration corridors are not protecting existing
employment land. Our client’s land interests at Bott Lane have been excluded from the identified local
employment areas. This is inconsistent with the current draft of the Lye and Stour Valley masterplan. The
masterplan acknowledges that the Engine Lane / Bott Lane area currently operates well as an area of
employment and recommends that the existing employment use is retained for the foreseeable future.

Comment

Representation ID: 436

Received: 19/01/2024

Respondent: Dudley Labour Group

REGEN CORRIDOR 13
In the previous Black Country Plan, the Regeneration Corridor 13 - Jewellery Line- Rowley Regis to Stourbridge Junction was an integral part of the regeneration corridor that ran through the Sandwell and Dudley area. The rail line, in parts, forms the boundary of Halesowen. The rail line, although termed Rowley Regis, also straddles the border of areas of North Halesowen and links the town via trains to London and beyond.

As Rowley Regis Station is literally yards from the Halesowen Town boundary, the Regeneration Corridor and the strategic rail has been instrumental in helping secure investment of two hundred plus new homes and business units in this northern part of Halesowen, off Cakemore Road and Nimmings Road.

Comment

Representation ID: 437

Received: 19/01/2024

Respondent: Dudley Labour Group

REGENERATION CORRIDOR 14

This corridor has been omitted. the revised Regeneration Corridor exercise undertaken by DMBC officers totally excludes the strategic location of Halesowen as an integral part of the revised Regeneration Corridor that was in existence as it was when it was in the Black Country Core Strategy Plan.

This oversight needs to be addressed as Halesowen Town should be benefiting regeneration funding streams to further unlock its potential as a key economic town of the Borough. Other Positive Attributes for it’s Inclusion in the Corridor.

Support

Representation ID: 445

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 2 Growth Network : Regeneration Corridors and Centres
We generally welcomed the strategic approach for the growth network including the focus on development within existing urban areas and Regeneration Corridors. Table 5.3 –
Regeneration Corridors, advises that Regeneration Corridor RC2, will keep its employment focus with strategic employment areas connecting centres, particularly Brierley Hill and Dudley. High quality housing will be focused in centres alongside the corridor with access to enhancing green infrastructure. Opportunities for canal side living in the corridor to Stourbridge, as well as potential local employment areas, will be pursued.

Comment

Representation ID: 511

Received: 19/12/2023

Respondent: Clowes Development LTD

Agent: Harris Lamb

Policy DLP2 – Clowes do not object to the proposed Regeneration Corridors being the primary focus for new development but, as stated in the policy, will not deliver the outstanding employment land requirement. Pensnett Trading Estate (PTE) is one of the “strategic employment areas” within a proposed Regeneration Corridor which extends towards South Staffordshire. Pensnett however has less than 5% spare capacity meaning there is very limited flexibility for growing businesses and redevelopment opportunities. Clowes’ site is only 3km from the centre of PTE, via the A491 and B4175.

Object

Representation ID: 553

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

2.6. This draft Policy sets out the Growth Network for the Borough, which it provides is intended to the be the primary focus for new development, regeneration, and infrastructure investment to support the delivery of significant growth and promote wider benefits to communities. Section 3 of the draft Policy confirms that Regeneration Corridors will provide a minimum of 4,948 new homes in sustainable locations.

2.7. The proposed Growth Network approach is supported, as this seeks to direct development to the most sustainable locations in the Borough, following on from the approach set out in adopted Policy including the Black Country Core Strategy and Dudley Borough Development Plan. Regeneration Corridor 2 in particular is strongly supported, as this extends through the heart of the Borough, linking the Strategic Centre of Brierley Hill to Stourbridge, a key Town Centre, through highly sustainable residential and employment areas. It is however suggested that the Council’s approach to this Regeneration Corridor is flawed, as it has failed to recognise the opportunity presented for residential development on Land at Corbetts Hospital, which is well located within walking distance of Stourbridge Town Centre and close to the public transport corridor along the A491, as well as close to a range of services and facilities. As the Plan seeks to allocate insufficient sites to accommodate the local housing needs, it is considered that the Council should be exploring fully all potential options within the identified Regeneration Corridors.

Object

Representation ID: 570

Received: 21/12/2023

Respondent: Charles Church Homes

Agent: Claremont Planning Consultancy

Policy DLP2 – Growth Network
2.6.
This draft Policy sets out the Growth Network for the Borough, which it provides is intended to the be the primary focus for new development, regeneration, and infrastructure investment to support the delivery of significant growth and promote wider benefits to communities. Section 3 of the draft Policy confirms that Regeneration Corridors will provide a minimum of 4,948 new homes in sustainable locations.
2.7.
The proposed Growth Network approach is supported, as this seeks to direct development to the most sustainable locations in the Borough, following on from the approach set out in adopted Policy including the Black Country Core Strategy and Dudley Borough Development Plan. Regeneration Corridor 2 in particular is strongly supported, as this extends through the heart of the Borough, linking the Strategic Centre of Brierley Hill to Stourbridge, a key Town Centre, through highly sustainable residential and employment areas. It is however suggested that the Council’s approach to this Regeneration Corridor is flawed, as it has failed to recognise the opportunity presented for residential development on Land at Corbetts Hospital, which is well located within walking distance of Stourbridge Town Centre and close to the public transport corridor along the A491, as well as close to a range of services and facilities. As the Plan seeks to allocate insufficient sites to accommodate the local housing needs, it is considered that the Council should be exploring fully all potential options within the identified Regeneration Corridors.

Comment

Representation ID: 613

Received: 22/12/2023

Respondent: Worcestershire County Council

Growth Strategy
The Draft DLP adopts an urban-led approach to growth, with the aim of delivering 10,876 new homes and at least 25ha of employment land, to create sustainable mixed communities supported by adequate infrastructure.
The emerging spatial strategy focusses growth and development at locations across the borough’s identified ‘Growth Network’ comprising town centres, existing urban areas and regeneration corridors.
Part 1 of the Draft Local Plan outlines the proposed growth strategy as follows:
• The Growth Network
o Brierley Hill Strategic Centre: 1,636 new homes
o Dudley Town Centre: 682 new homes
o Stourbridge Town Centre: 291 new homes
o Halesowen Town Centre: 261 new homes
o Regeneration Corridor 1: 585 new homes and 3.08ha employment
o Regeneration Corridor 2: 854 new homes and 7.73ha employment
o Regeneration Corridor 3: 514 new homes and 0.59ha employment
o Regeneration Corridor 4: 100 new homes and 4.1ha employment
• Outside the Growth Network: 377 new homes and 2.04ha employment
• Small windfall housing sites: 2,685 new homes
• Large windfall housing sites (Brierley Hill): 200 new homes
WCC Highways considers that focussing housing growth and development at sites in urban centres that are located in proximity to public transport corridors/services and employment opportunities, should offer the best opportunities for reducing the need to travel by private car. However, there may be a number of challenges for identifying and delivering necessary highways and transport infrastructure in relation to windfall housing sites (cumulatively amounting to a significant proportion of the total planned housing growth) where growth may be dispersed across the borough.
In terms of location, employment development often contributes significantly to peak-hour traffic, and hence there can be challenges to accommodating high levels of trip demand, which may only exist for limited periods of the day on the road network. The attraction to business of locating in highly accessible locations is recognised, and we are aware that for many businesses, close proximity to locally-strategic routes such as the A491 Hagley Road and A456 Birmingham Road is essential.
When considering the transport strategy supporting site allocations across the Growth Network and wider borough locations, WCC Highways requests that consideration is given to the planning of adequate transport infrastructure, including any necessary highway capacity improvements in Worcestershire to provide for cross-boundary movements.
Strategic Policies
WCC Highways welcomes the inclusion of a strategic transport policy that requires new development to actively promote active travel and sustainable transport and provide safe access for all users. WCC Highways considers the inclusion of a policy which requires new development proposals to assess their impact on the capacity of the transport network and which positively supports proposals that include mitigation against any unacceptable road safety or significant adverse congestion impacts, to also be beneficial.
Transport Evidence Base
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

Comment

Representation ID: 618

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: Glen Dimplex Group

Policy DLP2 (Growth Network: Regeneration Corridors and Centres)

The Brockmoor Foundry sites are located within a Regeneration Corridor, identified as the primary focus for new development, regeneration and infrastructure investment. As set out in the response to policy DLP1, it is agreed that Regeneration Corridors should be a focus for sustainable growth.

Part 3 should recognise that within the Regeneration Corridors, housing development should come forward as a mix of sized sites to ensure consistent delivery over the plan period, which will come together to achieve the strategy, including allocated and windfall sites. We recognise the need to strike a balance between the protection and enhancement of sustainable employment land and the releasing of brownfield land for housing delivery. We are supportive of the Council's approach to allocate underused employment land that would not be suitable for a modern occupier and therefore making efficient use of the land for housing delivery, as per Paragraph 119 of the NPPF.

Comment

Representation ID: 649

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of requirements 2e and 3g for “an improved network of green and environmental infrastructure”. This is a vital part of regeneration.
Page 2 of 9
We also welcome the additional description in table 5.2 -
Brierley Hill strategic centre
We welcome the following points:
• …imaginatively landscaped and well-connected public spaces
• being a much greener place, with increased tree cover and more biodiversity including wildlife corridors, which is better linked to the Saltwells and Fens Pool Nature Reserves.
• … well designed public open spaces around them
• having a high quality and beautiful built, natural, and historic environment that respects and enhances local character, including important historic buildings and areas, and makes effective use of the canal network as an asset.
Stourbridge town centre
Halesowen town centre
We welcome the references to the river Stour and the canals in the opportunities sections for Stourbridge and Halesowen. It would be good if this could come through more strongly in the vision.
RC2 – Dudley to Brierley Hill to Stourbridge
We welcome the reference to the canals, the river Stour and to Fens Pool nature reserve. Fens Pool is a Special Area of Conservation. The Habitat Regulations Assessment needs to be utilised here in order to ensure plans and policies do not result in adverse effects on integrity.
RC3 – Stourbridge to Lye
We welcome the reference to the river Stour and note the production of the Lye and Stour Valley design code.
RC4 – Dudley to Coseley
We welcome the proposed enhancement of open spaces including Wren’s Nest National Nature Reserve.

Comment

Representation ID: 686

Received: 15/12/2023

Respondent: National Highways

We note that a Sustainability Appraisal process has been undertaken to streamline the different housing and employment growth options and acknowledge that the allocation of sites has taken into consideration the location, availability of greenfield/ brownfield sites and sustainability elements. We note that the new development allocations are focussed within the Regeneration Areas and Centres, which is likely to lead to a more efficient use of land and in improving the sustainable travel options.

Comment

Representation ID: 689

Received: 22/12/2023

Respondent: Canal and River Trust

In Policy DLP2 Growth Network: Regeneration Corridors and Centres, the Trust considers that sub-heading e) could be augmented with explicit mention of sustainable travel and encouragement of modal shift, and potential amalgamation of sub-heading g) as a mechanism for delivery.

Comment

Representation ID: 791

Received: 30/01/2024

Respondent: Historic England

DLP2. The policy would benefit from a reference to the historic environment and how this will be factored into the growth options the Council are pursuing.
Page 63. Beneficial reference to the canal network. Are there any other specifics for the historic environment that the policy will seek to protect/enhance?
Page 64. Beneficial reference to historic town of Dudley. Are there any other specifics for the historic environment that the policy will seek to protect/enhance?
Stourbridge/Halesowen Centres Page 64-65. Are there any specifics relating to the historic environment of these areas that can be referenced and opportunities the Plan is seeking.
Table 5.3. Has there been any assessment of these proposals on the impact of the historic environment and the opportunity for conserving and enhancing heritage assets.

Support

Representation ID: 849

Received: 19/12/2023

Respondent: Sport England

Support for part 2 references but would note there is some need for flexibility in application of the policy.

Support for part 3d references.