Object

Representation ID: 308

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 3 Areas Outside the Growth Network
Part 5 of the policy confirms that the Council’s Green Belt boundaries will be maintained and protected from inappropriate development. In light of the comments, we have set out in respect of policy DLP 1 above Barberry object to this approach on the basis that maintaining the Green Belt and seeking to direct growth to only previously developed sites will result in housing need being unmet and a shortage of employment land being delivered through the Plan unless the Council is able to agree with other authorities in the HMA for them to accommodate some of this unmet need. As noted previously the Council had intended to release land from the Green Belt when preparing the Black Country Plan in order to not only meet Dudley’s needs but contribute to meeting the wider needs of the HMA. Barberry reiterate that the release of land from the Green Belt within Dudley will help ensure that Dudley is able to meet its housing requirement of 11,954 in full within its own administrative areas without having to resort to its adjoining neighbours. The decision to not release land from the Green Belt to meet Dudley’s needs in full will have a number of adverse consequences for the supply of new homes and particularly the delivery of affordable homes, making the aspiration for home ownership beyond the reach of many who live in the Borough.

Comment

Representation ID: 326

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

We are not clear what is meant by allocations on surplus land? Surplus land according to whom and how is this defined?

Given that 96.4% of the proposed allocations in the Borough are on brownfield land and just 3.6% of the supply on greenfield, we would question whether these developments will be able to deliver the infrastructure requirements stipulated elsewhere given the likely viability constraints impacting these sites. Whilst we support the ‘brownfield first’ approach, we consider that where possible, those allocations should be augmented with greenfield sites in order to ensure that sufficient affordable housing and infrastructure contributions are also made.

We also note that there has been a lapse rate allowance of 10% discounted to allow for some sites which may not come forward over the course of the plan. We would like to know whether this truly represents the historic lapse rate pattern, as we are aware of a substantial number of sites within Dudley Borough that have not come forward because of persistent viability problems associated with heritage, site contamination and other issues which include tensions between commercial/industrial land values being similar to those of residential (post-remediation). We are not clear whether this has been considered carefully enough.

Given the diminishing availability of grant funding, it is clear that the situation is unlikely to be resolved any time in the near future. Development viability will continue to be undermined by higher interest rates; high build costs and high land costs for some time to come. Bringing forward a more balanced portfolio of brownfield and greenfield sites will allow a steady supply of new homes and allow Dudley to maintain a 5 year housing land supply throughout the course of the plan period. At the present time, we are not convinced that the current strategy will work.

Object

Representation ID: 375

Received: 21/12/2023

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Policy DLP 3 Areas Outside the Growth Network
Part 5 of the policy confirms that the Council’s Green Belt boundaries will be maintained and protected from inappropriate development. In light of the comments we have set out in respect of policy DLP 1 above WL object to this approach on the basis that maintaining the Green Belt and seeking to direct growth to only previously developed sites will result in housing need being unmet and a shortage of employment land being delivered through the Plan unless the Council is able to agree with other authorities in the HMA for them to accommodate some of this unmet need. As noted previously the Council had intended to release land from the Green Belt when preparing the Black Country Plan in order to not only meet Dudley’s needs but contribute to meeting the wider needs of the HMA. WL reiterate that the release of land from the Green Belt within Dudley will help ensure that Dudley is able to meet its housing requirement of 11,954 in full within its own administrative areas without having to resort to its adjoining neighbours. The decision to not release land from the Green Belt to meet Dudley’s needs in full will have a number of adverse consequences for the supply of new homes and particularly the delivery of affordable homes, making the aspiration for home ownership beyond the reach of many who live in the Borough.

Comment

Representation ID: 394

Received: 22/03/2024

Respondent: Home Builders Federation

Agent: Home Builders Federation

HBF reiterates that it does not comment individual sites or allocations but does support the need for the Plan to provide for a wide range of deliverable and developable sites and to ensure that housing needs are met in full. The Plan need to ensure there is a sufficiency of Housing Land Supply (HLS) to meet the housing requirement, ensure the maintenance of a 5 Year Housing Land Supply (5YHLS) and achieve Housing Delivery Test (HDT) performance measurements. HBF cannot see how achieving these aims is possible without Green Belt release. It is noted that this may in turn also effect the spatial strategy for the Local Plan.

Comment

Representation ID: 479

Received: 19/01/2024

Respondent: CPRE Worcestershire

West Midlands CPRE strongly support the protection and enhancement of Green Infrastructure and the maintenance of Green Belt boundaries as well as the emphasis on providing development in sustainable locations as set out Parts 4, 5 and 6 of Policy DLP 3.

Comment

Representation ID: 495

Received: 22/12/2023

Respondent: Feoffess of Oldswinford Hospital (Foundation)

Agent: Turley

2.14 The Foundation supports Policy DLP3 in principle but has concerns in respect of the emphasis on development outside the growth network on brownfield land only. NPPF paragraph 109 notes that new development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This paragraph does not limit new development to brownfield sites only.

2.15 The DLP Site Assessment Report (October 2023), confirms that in accordance with the preferred spatial strategy of the DLP, only sites in the urban area of the Borough have been assessed for potential development, with a focus on brownfield land. This approach excludes potential development opportunities in areas outside the urban boundary, including those within the Green Belt. This methodology falls short of providing a comprehensive assessment of all available land within the Borough.

2.16 Whilst Green Belt is a designation that should be balanced as part of the site selection process, it should however not be treated as a ‘gateway constraint’ and essentially a determinative factor as to whether a site is suitable.

2.17 Beyond the site selection process and use of Green Belt as a ‘gateway constraint’, there is no evidence to demonstrate that the DLP’s previously developed land only strategy will deliver the level of housing indicated. It is well evidenced that developing brownfield land comes with significant costs which impact viability, and longer lead in times due to the need for site clearance and demolition; site remediation; service diversions etc.

2.18 Additionally, brownfield sites offer high levels of density, leaving little space for new family homes with gardens. Lichfield’s Banking on Brownfield report (June 2022) states that 48% of the homes on proposed sites on the register are likely to be apartments (sites of over 100dpa) whereas just 17% of households across the country are likely to live in apartments. This does not represent a balanced housing tenure and size offer.

2.19 As stated in Lichfield’s Start to Finish Report (February 2020), large greenfield sites deliver quicker and more importantly, deliver at a quicker rate than brownfield sites. The DLP Viability Assessment notes that greenfield sites have an additional transactional step where the land promoter or master developer will have to sell the site (or phases/parcels) to a housebuilder before the detailed planning application stage can commence. However, the Foundation is the sole owner of both Racecourse Lane and Worcester Lane, eliminating the need for this additional transactional step. This single ownership streamlines the development process, potentially accelerating the delivery of housing on these sites.

2.20 Paragraph 5 in DLP3 confirms that Dudley's Green Belt boundaries will be maintained and protected from inappropriate development. As highlighted in the response to Policy DLP1, there exists a pressing need for new housing within the Borough and the wider housing market area. The Foundation believes that achievable and deliverable greenfield sites in the Green Belt, beyond the Growth Network, including land at Racecourse Lane and Worcester Lane which, amount to an ‘urban extension’ and not a clear intrusion into the Green Belt being surrounded and adjacent to an established settlement, can contribute to sustainable development and reduce Dudley’s unmet housing need.

Support

Representation ID: 520

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Glen Dimplex support the inclusion of such a policy which provides guidance for those sites outside of the identified Growth Network, which could play an important role in delivering the housing and employment requirements of the Borough, particularly in response to changing markets.

Support

Representation ID: 650

Received: 22/12/2023

Respondent: Natural England

Natural England welcomes the inclusion of point 4, particularly the reference to green and blue infrastructure and bringing this into the heart of the urban area:
4. Improved green and blue infrastructure, linked with protected Green Belt will promote health and wellbeing, support biodiversity and will bring the countryside and its landscape into the heart of the urban area.

Comment

Representation ID: 690

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests incorporation of cross-referencing to Canal Policy DLP36 within the justification text to Policy DLP3 to identify our network’s inclusion as a suitable recipient for improvements listed in sub-heading 4. (ACTION REQUEST).

Comment

Representation ID: 792

Received: 30/01/2024

Respondent: Historic England

DLP3. The policy would benefit from a clause relating to the historic environment.

Support

Representation ID: 851

Received: 19/12/2023

Respondent: Sport England

Support for parts 1b and 4 of the policy. Suggest text is added to the justification related to physical activity and health and well-being.

Support for part 6 of the policy.