Comment

Representation ID: 1245

Received: 05/12/2024

Respondent: Bromsgrove District Council

The Duty to Cooperate (DtC) has been unsuccessful in providing solutions to meeting the wider needs of the Greater Birmingham and Black Country Housing Market areas over many years. This fact and the lack of clarity in the current plan remain a concern. With the return to a more formal regional planning regime looking increasing likely, finding a solution to if/how the full housing needs of the West Midlands can be met should be progressed though this route, and not continue in the ad hoc manner as is currently taking place. A solution will need to be found by LPA's including Dudley, which allows plans to be put in place to ensure that plan led development can continue in the shorter term, but which also allows for a Spatial Development Strategy (SDS) to progress and solve those strategic issues which have failed to be solved under the (DtC).

Comment

Representation ID: 1246

Received: 05/12/2024

Respondent: Bromsgrove District Council

In order for the plan to be made sound we would suggest that the Dudley MBC withdraws the current draft plan. Following the publication of the new NPPF, and once more clarity around the role and scope of SDS's is provided, Dudley MBC can then draft and publish a plan under reg 19 which is informed by the planning framework it will be examined against.

Comment

Representation ID: 1258

Received: 06/12/2024

Respondent: South Staffordshire Council

The proposed changes to the NPPF have recently been the subject of consultation and it is the Government’s intention to publish a finalised NPPF by the end of the year. Based on the transitional arrangement contained in the consultation NPPF it is our understanding that the Plan would need to be submitted on or before the publication of the revised NPPF (+ one month) if it is to be assessed against the current December 2023 NPPF. Should the Plan be submitted after NPPF publication date (+ one month) it would appear that the Plan would be considered in relation to the revised framework, as it doesn’t appear that any of point a-c in paragraph 226 of the draft NPPF would apply to DMBC. This would require DMBC to re-examine the current plan strategy particularly in light of the proposed introduction of a distinction between Green Belt and Grey Belt land, and the role which Green Belt can play in increasing the supply of land for residential development and Gypsy and Traveller provision. Therefore, whilst the plan is currently considered sound against the December 2023 NPPF, should the transitional arrangements in paragraph 226 of the consultation NPPF remain in the final version, and should DMBC be unable to meet any of points a-c in this paragraph, then the Publication Plan would not be sound and would need to be revisited.

Comment

Representation ID: 1265

Received: 06/12/2024

Respondent: Stratford District Council

Para 3.30-3.35 of the Local Plan notes that Dudley Council has been working collaboratively with neighbouring authorities on cross-boundary issues for a number of years and will continue to do so. Para 3.33 refers specifically to Statements of Common Ground (SoCG), stating that draft SoCGs have been produced to support the current Local Plan stage on key Duty to Cooperate issues. These are to be formalised prior to Submission of the Plan. SDC look forward to working with DMBC on a SoCG in due course, whether this be a bilateral statement between the two authorities or through a joint GBBCHMA SoCG.
It is noted that a separate Duty to Co-operate Statement (dated October 2024) has been prepared to support the Publication stage version of the plan. Appendix 4 records Dudley MBC’s correspondence with Stratford DC at Dudley’s Regulation 18 stage1

Comment

Representation ID: 1271

Received: 06/12/2024

Respondent: Stratford District Council

Given that the proposed plan period for the Dudley Local Plan extends to 2041, which is beyond the 2031 horizon of the 2018 Growth Study, the planned update to the sub-regional work is required to provide an updated picture covering the entire plan period. There is no mechanism within the Publication Version of the Dudley Local Plan as drafted to respond to the planned work of the GBBCHMA regarding quantifying and apportioning the shortfall in homes across the Housing Market Area through the proposed Growth Study refresh. It is therefore currently unclear how this strategic work could influence the Dudley Local Plan and be effective in assisting with meeting the identified housing shortfall.

Comment

Representation ID: 1273

Received: 06/12/2024

Respondent: Stratford District Council

We welcome the Council’s commitment at para 5.13 of the Local Plan to continuing to work constructively with neighbouring authorities to help provide as much certainty as possible about how and where the borough’s full housing and employment land needs will be delivered. However, it is unclear how this continued work will inform the Local Plan as it progresses to Submission stage and subsequent examination. We note that a Statement of Common Ground is planned with members of the GBBCHMA regarding the apportionment of any contributions between the GBBCHMA authorities and agreement to refresh the 2018 HMA Strategic Growth Study. Stratford DC look forward to assisting with this in the coming months. We also note that the expected forthcoming publication of a revised NPPF will result in further consideration on this topic.
We would also reiterate that there are infrastructure pressures in both South Warwickshire districts and neither have sufficient infrastructure or the funds to cater for significant additional population, particularly in respect of health, education, and transport infrastructure. It would be necessary for any exported housing to be accompanied by sufficient, funded resources to provide for these.
Stratford on Avon District Council (with Warwick District Council) reiterate their ongoing commitment to working with Dudley Council on strategic matters that cross administrative boundaries under the requirements of the Duty to Cooperate.

Object

Representation ID: 1274

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The publication of the Draft Plan comes at a time of changing national planning policy, including reforms introduced by the 2023 Levelling Up and Regeneration Act, which the Council has partially acknowledged but not fully integrated into the draft Plan. The upcoming reforms, particularly those related to housing need calculations and Green Belt reviews, will have significant implications for Dudley, increasing the housing requirement to nearly 1,600 dwellings annually, up from 657. While transitional arrangements may allow the Council to avoid some of these changes, it is crucial that the emerging Plan acknowledges these policy shifts and prepares for future challenges. The draft Plan's timetable for submission in 2025 and adoption by 2026 is seen as unrealistic, given the average duration of local plan examinations.

The Council must ensure the Plan is robust to meet these deadlines, but there are concerns about the Duty to Co-operate and uncertainties about how unmet housing needs, both locally and in neighbouring authorities, will be addressed. Additionally, the housing allocations in the draft Plan are considered insufficiently robust and likely to face challenges during examination. The timescales for the Plan’s progression offer no buffer for delays in submission or examination, and further consultations or evidence may be required. As a result, the plan period should be reconsidered to ensure it extends beyond 15 years post-adoption, in line with national policy requirements.

Object

Representation ID: 1275

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The draft Plan fails to fully consider the national policy changes expected to be implemented before its submission, and the Council should review its approach in light of these changes. At a regional level, the Plan does not adequately address the ongoing challenges in the Black Country, including unmet housing needs from neighbouring authorities such as Birmingham, Wolverhampton, and Sandwell, with significant uncertainty about how these needs will be met. Additionally, there is concern that Dudley should contribute to addressing these regional housing needs due to its proximity and functional relationships with neighbouring areas. The Plan also overlooks the need for sufficient employment land, especially smaller-scale sites that are necessary to free up housing allocations, and the Council must ensure realistic expectations for employment land delivery.

Support

Representation ID: 1276

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

The proposed Vision for the Borough is generally supported, but balancing all aspirations, especially conflicting ones like affordable housing and green spaces, will be challenging. Additionally, the Plan's proposed period to 2041 risks falling short of the required 15-year period post-adoption, so the Council should extend the plan period to account for potential delays and ensure compliance with national policy.

Comment

Representation ID: 1278

Received: 06/12/2024

Respondent: Birmingham City Council

The City Council would still assert that the high levels of unmet need being experienced across the Conurbation and the wider Birmingham and Black Country HMA could be considered as exceptional enough to warrant a Green Belt boundary alteration in line with Paragraph 145 of the existing NPPF (December 2023). In addition, the ‘soundness’ requirements set out in paragraph 35 of the NPPF, which requires plans to be positively prepared in providing a strategy which seeks to meet the area’s objectively assessed needs, will also have to be considered when preparing the DLP for submission.
In July 2024, the change in Government brought about a new draft of the NPPF for consultation as well as a proposed revision to the methodology in calculating housing need for local authorities. As mentioned earlier, the proposed methodology will result in a significant reduction in the housing requirement for Birmingham but results in proposed increases to housing need in other local authority areas at a significant level including Dudley (although there is little difference in the overall need across the GBBCHMA as a whole). These changes are yet to be fully adopted following consultation but, if adopted, would add further weight to the need for Dudley to reconsider the Spatial Strategy of the DLP and reintroduce housing sites previously considered.
The transitional arrangements for the introduction of the proposed new NPPF and their effects on Local Plans have still to be confirmed, but further consideration will need to be given to these arrangements when they are expected to be published at the end of 2024. If the Plan meets the criteria for further progression set out in the transitional arrangements, then the City Council must also consider the effects of the potential change in housing needs methodology and its impact on future housing requirements and the spatial strategy for Dudley. If the DLP does proceed towards submission and potential adoption under these transitional arrangements, then the City Council would strongly promote the need for an early review of the DLP to ensure future housing needs are fully explored and appropriately planned for going forwards to ensure the needs of the GBBCHMA are met as a whole.

Comment

Representation ID: 1286

Received: 06/12/2024

Respondent: Worcestershire County Council

We note that the Policies Map recognises the A491 and A456 but does not acknowledge the potential for cross-boundary movements utilising the A451 and B4551. However, these routes are included in the transport modelling report. We support the preferred approach (para 3.35) that the unmet housing and employment land needs can be met without requiring development opportunities in the Worcestershire County Council local authority area. However, given the proximity of the Plan area to Worcestershire and the key highway links connecting the county to Dudley
5
Borough, there is the potential for cross
-boundary movement to utilise Worcestershire’s transport network, particularly the A491 Hagley Road and A456 Birmingham Road, but also the A451 Stourbridge Road and B4551 Bromsgrove Road. Therefore, mechanisms need to be identified to determine the potential impacts on these routes and the associated solutions to those impacts.

Support

Representation ID: 1287

Received: 06/12/2024

Respondent: Worcestershire County Council

We support the principles in the vision of sustainable urban growth, more accessibility and promoting more active forms of travel, especially public transport and a network of footpaths and cycleways providing connections to the countryside around the borough (para 4.1). We also support (Table 4.1) Strategic Priority 7 - Delivering the resources, infrastructure and services to support growth by: successfully addressing borough-wide infrastructure needs and maximising the efficient use of existing infrastructure capacities; exploring opportunities for new sustainable infrastructure, including through delivering an enhanced footpath and cycleway network within the borough; and ensuring appropriate and timely delivery of infrastructure to support new developments.

Comment

Representation ID: 1295

Received: 06/12/2024

Respondent: Worcestershire County Council

WCC welcomes this acknowledgement of the A491, however the infrastructure schedule (Part 2 – Infrastructure Delivery Schedule) which accompanies the IDP document, and which identifies numerous transport schemes for active travel, public transport, and highways at the strategic and local level, does not include capacity improvements and/or mitigation measures for cross-boundary movements with WCC.
In the absence of a Monitor and Manage policy commitment, the current uncertainties of future travel patterns are such that WCC are concerned that unacceptable impact may arise. Modifications to policy text (adequate ‘Monitor and Manage’ processes) would address this and help to provide surety that development would not have any unacceptable cross-boundary highway impacts.

Comment

Representation ID: 1296

Received: 06/12/2024

Respondent: Worcestershire County Council

As set out in our Regulation 18 response (December 2023), WCC has concerns that the PRISM model network does not extend to Hagley or the northern-most extents of Worcestershire’s highway network (except for the 1km buffer around the study area). WCC would seek to review the PRISM transport model, Local Model Validation Report, data collection reports and any forecasting reports. As such, and without sight of the above-mentioned information, this confirms the need for a ‘Monitor and Manage’ approach to help to provide surety that development would not have any unacceptable cross-boundary highway impacts

Comment

Representation ID: 1300

Received: 27/11/2024

Respondent: National Grid Electricity Transmission

Agent: National Grid Electricity Transmission

About NGET:

NGET owns and maintains the electricity transmission system in England and Wales.
National Grid Ventures (NGV) develops and invests in energy projects separately from NGET.
Consultation and Guidance:

NGET emphasizes the importance of consulting them on any development plans that might affect their assets.
They advocate for high standards of design and sustainable development around their high voltage overhead lines.
Utilities Design Guidance:

NGET provides guidelines for development near their assets to ensure safety and minimize impact.
They retain existing overhead lines but may consider changes for significant proposals.
Further Advice:

NGET offers to provide advice and guidance to the Council and developers.
They stress the importance of maintaining statutory safety clearances around their infrastructure.
Contact Information:

NGET provides contact details for further information and consultation.

Comment

Representation ID: 1302

Received: 28/11/2024

Respondent: Home Builders Federation

The council must carefully consider the impact of changes to the NPPF and the standard method on their Local Plan. If the Dudley Local Plan is submitted under current transitional arrangements, the council must assess the implications for their plans and those of neighbouring areas, as part of the Duty to Cooperate.

Key points include:

Para 226(a) of the draft NPPF: Policies apply to local plans unless the plan reaches Regulation 19 stage by a specific deadline and is within 200 dwellings of the new Local Housing Need figure. This does not apply to the Dudley Local Plan, so the council must update their housing need calculations to avoid delays.
Minimum housing need: The Dudley Local Plan must plan for at least 1,394 homes, reflecting the most current data.
Limited weight of proposed NPPF amendments: Although these amendments currently hold limited weight, inspectors are already considering them during Local Plan examinations. The Dudley Local Plan may need an immediate review if submitted before these changes are implemented.

Comment

Representation ID: 1303

Received: 28/11/2024

Respondent: Home Builders Federation

The proposed changes to national policy by the Government will require the Dudley Local Plan to be modified for an immediate review to account for these changes. If the changes remain as proposed, paragraph 227 of the draft NPPF will need to be considered, which expects local plans with housing requirements significantly below the Local Housing Need figure to start new plan-making promptly to address any shortfall.

The Home Builders Federation (HBF) emphasizes the importance of minimizing unmet housing needs and proactively planning to meet national housing goals. They believe the current Dudley Local Plan is not adequately addressing these objectives and is therefore unsound.

Comment

Representation ID: 1304

Received: 28/11/2024

Respondent: Home Builders Federation

The Plan is considered unsound because it is not justified, effective, or aligned with national policy. The Home Builders Federation (HBF) notes that the Plan Period only extends to 2041, while the NPPF requires strategic policies to cover at least 15 years from adoption. Given the time required for plan preparation and adoption, HBF suggests extending the plan period by one or two years to meet this requirement. They emphasize that the evidence base should also reflect this extended timeframe to ensure the plan's soundness.

Comment

Representation ID: 1305

Received: 28/11/2024

Respondent: Home Builders Federation

Duty to Cooperate: The Home Builders Federation (HBF) appreciates the Council's efforts to update the Local Plan but is disappointed that it does not adequately plan for Dudley's future growth, including housing and jobs. Key concerns include:

- **Lack of regional cooperation**: The West Midlands has a history of poor strategic planning and unmet housing needs.
- **Under delivery of housing**: There has been a consistent failure to meet housing objectives due to insufficient cooperation.
- **Duty to Cooperate**: The current approach may continue this trend, leaving housing needs unmet. The Council should not plan in isolation but consider the wider West Midlands context.
- **Plan period and housing needs**: The plan period may need extending, and the Council should ensure it meets its own housing needs without relying on neighboring authorities.
- **Proactive planning**: The Council must demonstrate ongoing cooperation and address potential unmet needs to meet national housing goals.

HBF suggests a broader, more cooperative approach to planning, including a potential green belt review, to ensure the Local Plan is effective and sound.

Comment

Representation ID: 1306

Received: 28/11/2024

Respondent: Home Builders Federation

The Home Builders Federation (HBF) raises concerns about the Shropshire Local Plan Examination in Public (EIP), noting that inspectors have questioned its soundness and canceled future hearings. This casts doubt on Dudley's reliance on Shropshire to meet some of its housing needs.

HBF seeks the Council's view on how these developments affect the Duty to Cooperate and suggests updating the Duty to Cooperate statement to reflect the current situation. They emphasize the importance of Dudley meeting its own housing needs, as the current plan indicates significant unmet need.

Comment

Representation ID: 1307

Received: 28/11/2024

Respondent: Home Builders Federation

The Home Builders Federation (HBF) finds the Vision for Dudley unsound as it lacks justification, effectiveness, and alignment with national policy. Key points include:

- **Housing Provision**: The Vision should explicitly include the need for market and affordable housing to address the housing crisis and support growth aspirations.
- **Plan Objectives**: Meeting housing needs in full should be a primary objective, potentially requiring a Green Belt review. The objectives should recognize the link between housing and economic growth, emphasizing the importance of providing enough homes to support Dudley and the wider West Midlands region.

Comment

Representation ID: 1337

Received: 28/11/2024

Respondent: Home Builders Federation

Dudley Local Plan: Part Two - HBF's Summary and Comments:

Site Allocation:

HBF does not comment on individual sites but stresses the importance of providing a wide range of deliverable and developable sites to ensure competition, choice, and a buffer to fully meet housing needs. The soundness of site allocations, whether brownfield or greenfield, will be evaluated during the Local Plan Examination.
Biodiversity Net Gain (BNG):

HBF suggests that the implications of BNG should be considered in the plan allocation process, referring to their earlier comments in Part One of the Dudley Plan.
Participation in Local Plan Examination:

HBF requests to participate in the Hearing Sessions of the Local Plan Examination to ensure the home building industry can address housing-related issues raised during the sessions.
Future Engagement:

HBF expresses its willingness to discuss the issues further or facilitate broader discussions within the home building industry as the plan progresses.

Object

Representation ID: 1350

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENTS ON OMISSION SITE MADE TO TABLE 6.1 OF PART TWO DUDLEY LOCAL PLAN AND EVIDENCE BASE (SHLAA, GREEN BELT REVIEW, SUSTAINABILITY APPRAISAL).

Consider omission Green Belt site (Land north of Sandyfield Road, Sedgley) should be assessed in the Strategic Housing Land Availability Assessment 2023/24. Site forms part of a wider parcel (BL10) in the Black Country Green Belt review (the part that falls within Dudley borough- remainder of site in South Staffordshire).

The Green Belt Review has not been updated or revisited since 2019 despite the housing requirement changing.

The site should be assessed as a reasonable alternative within the Sustainability Appraisal.

Vision Document for the site submitted in support of its promotion.

Object

Representation ID: 1351

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENT ON SUSTAINABILITY APPRAISAL

Do not agree with the reasoning for the selection of 'Housing Option 3' for meeting housing spatial growth. Housing need is not addressed. There is no balance as there is a particular focus on brownfield land (97% of supply). Brownfield land will not deliver the affordable housing needed- viability concerns generally. Council should consider which sites have a realistic chance of delivery. Council should not pursue a growth option where they cannot accommodate of their own growth needs without Green Belt release and rely on neighbouring authorities. The Sustainability Appraisal (SA) states the impacts of the exported unmet need cannot be fully assessed - the SA is incomplete because the strategy is flawed.

Object

Representation ID: 1352

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENTS ON CROSS BOUNDARY ISSUES AND DUTY TO COOPERATE (SECTION 3.30 OF DLP)

Summarises history and latest position in respect of potential housing contributions from other local authorities. Concerned that up to date Statements of Common Ground are missing from the consultation- difficult to assess what work has been undertaken to agree revised contributions and distribution of housing needs. Concerned that neighbouring authority plans have reduced housing requirements. Unclear where the unmet housing needs of the wider housing market area will be met. Query why the Council have reduced the number of homes to be accommodated within the borough and whether are complying with the Duty to Cooperate. No clear evidence that the Council have an agreed approach to the strategic delivery of housing and Green Belt review and release.

Consider there has been a failure between the neighbouring Black Country Authorities and Dudley MBC, as well as South Staffordshire, Bromsgrove and Birmingham in the Duty to Cooperate.

The Council has not met its obligations under the Duty to Cooperate or met the tests set out at Paragraph 35 of the NPPF.

Comment

Representation ID: 1353

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Strategic Objective 1:
Agree with aim of Strategic Priority 1 to address the climate and ecological emergency. Partially agree with Strategic Priority 2 - question how elements related to biodiversity and ecological network enhancements will be mandated and the level of viability testing undertaken in regards to off-site improvements. Disagree with Strategic Priority 3 as if more Green Belt was released for residential development, there would be the opportunity to contribute towards the Councils' Duty to Cooperate on delivering housing.

Strategic Objective 2:
Agree with this and Strategic Priority 4.

Strategic Objective 3:
Agree with the Objective. Agree with Strategic Priority 5. Partially agree with Strategic Priority 6 in terms of meeting housing needs, but consider the Council should contribute to the unmet needs of the Greater Birmingham area. Agree with Strategic Priority 7. Agree with Strategic Priorities 8 and 9 but the Duty to Cooperate is essential in identifying and delivery cross-boundary infrastructure to facilitate unmet housing needs from neighbouring authorities.

Object

Representation ID: 1360

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The publication of the Draft Plan comes at a time of changing national planning policy, including reforms introduced by the 2023 Levelling Up and Regeneration Act, which the Council has partially acknowledged but not fully integrated into the draft Plan. The upcoming reforms, particularly those related to housing need calculations and Green Belt reviews, will have significant implications for Dudley, increasing the housing requirement to nearly 1,600 dwellings annually, up from 657. While transitional arrangements may allow the Council to avoid some of these changes, it is crucial that the emerging Plan acknowledges these policy shifts and prepares for future challenges. The draft Plan's timetable for submission in 2025 and adoption by 2026 is seen as unrealistic, given the average duration of local plan examinations.

The Council must ensure the Plan is robust to meet these deadlines, but there are concerns about the Duty to Co-operate and uncertainties about how unmet housing needs, both locally and in neighbouring authorities, will be addressed. Additionally, the housing allocations in the draft Plan are considered insufficiently robust and likely to face challenges during examination. The timescales for the Plan’s progression offer no buffer for delays in submission or examination, and further consultations or evidence may be required. As a result, the plan period should be reconsidered to ensure it extends beyond 15 years post-adoption, in line with national policy requirements.

Object

Representation ID: 1361

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The draft Plan fails to fully consider the national policy changes expected to be implemented before its submission, and the Council should review its approach in light of these changes. At a regional level, the Plan does not adequately address the ongoing challenges in the Black Country, including unmet housing needs from neighbouring authorities such as Birmingham, Wolverhampton, and Sandwell, with significant uncertainty about how these needs will be met. Additionally, there is concern that Dudley should contribute to addressing these regional housing needs due to its proximity and functional relationships with neighbouring areas. The Plan also overlooks the need for sufficient employment land, especially smaller-scale sites that are necessary to free up housing allocations, and the Council must ensure realistic expectations for employment land delivery.

Support

Representation ID: 1363

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

The proposed Vision for the Borough is generally supported, but balancing all aspirations, especially conflicting ones like affordable housing and green spaces, will be challenging. Additionally, the Plan's proposed period to 2041 risks falling short of the required 15-year period post-adoption, so the Council should extend the plan period to account for potential delays and ensure compliance with national policy.

Object

Representation ID: 1388

Received: 09/12/2024

Respondent: Clowes Development LTD

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

Paragraph 2.44 of the Duty to Cooperate Statement makes reference to the Black Country Authorities (BCAs) seeking to come to an agreement via a statement of common ground on how to apportion contributions to BCAs as a whole from neighbouring LPAs. As the BCAs are no longer progressing a joint Local Plan, Dudley should be approaching each LPA who has offered a housing contribution for them to provide a number for Dudley only. It is not just for BCAs to decide how to apportion this, but it should also reflect the specifics of the functional and administrative relationships between LPAs.
In respect of Dudley and South Staffordshire there is a particularly strong administrative relationship, due to the fact that Dudley shares around a third of its administrative boundary with South Staffordshire, and of that the majority of the Dudley built up area is up to the boundary with South Staffordshire, as is shown in the map overleaf: Functionally, Dudley and South Staffordshire are connected by proximity and key connections such as the A449 and A458, and the Shrewsbury to Birmingham railway line (via Coseley railway station).We note that another way Dudley intends to evidence constructive engagement is through the publication of evidence such as that seen at appendices one and two of the DtC Statement. A number of meetings are recorded as having taken place with Duty to Cooperate partners. This lists out a number of meetings with different partners. A key issue is that none of the recorded instances of these meetings takes place in 2024, which suggests a lack of ongoing engagement (as required by paragraph 26 of the NPPF).
To evidence that this engagement has been meaningful, the minutes, actions and outcome of these meetings referenced in appendix one and two of the DtC statement, should be made public (albeit redacted where necessary). This would then suitably evidence cooperation. Otherwise it is not clear whether meetings have been useful in satisfying the requirement for ongoing and meaningful engagement.
We ask the BCAs to publish detailed minutes, lists of attendees etc. for the meetings referenced in appendix one and two, and furthermore provide a clear indication of the level of engagement that has been taking place with HMA LPAs.
Summary and Key Points for Dudley to Consider
Having reviewed and considered the evidence base made available in relation to the Duty to Cooperate, we assert that the following key points should be taken forward to ensure that the Local Plan review’s position in respect of Duty to Cooperate is legally compliant, and also sound as per paragraph 35 of the NPPF:
Specific engagement should be made with South Staffordshire, due to its strong administrative and functional relationship with Dudley.
SoCGs should be drafted and regularly updated now, as recommended by the PPG.