Comment

Representation ID: 1586

Received: 29/11/2024

Respondent: Historic England

Table 6.1 Housing Allocations

There are a number of housing allocations which are proposed that will have an impact on heritage assets and the require appropriate mitigation. There is no reference to the HIA for these sites and any proposed mitigation measures that would be required to overcome any harm. How will the Plan deal with this issue? How will planning officers and prospective developers know what issues need to be considered prior to determining planning applications?

Comment

Representation ID: 1587

Received: 29/11/2024

Respondent: Historic England

Table 8.1 Employment Allocations

There are a number of employment allocations which are proposed that will have an impact on heritage assets and the require appropriate mitigation. There is no reference to the HIA for these sites and any proposed mitigation measures that would be required to overcome any harm. How will the Plan deal with this issue? How will planning officers and prospective developers know what issues need to be considered prior to determining planning applications?

Support

Representation ID: 1597

Received: 29/11/2024

Respondent: National Highways

Agree in principle to the vision and objectives of the Plan.

Object

Representation ID: 1599

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

GLOSSARY

The PCCWM objects. The PCCWM has mentioned the need for a definition of infrastructure at various points within this response. The current glossary fails to mention the emergency services and this omission should be rectified, as highlighted above, as follows:

“Infrastructure: Generic term to describe structures or buildings, services and facilities which support residents, animals and nature residing in certain areas. This could be in terms of transport, for example walking, cycling paths and public transport infrastructure, in social infrastructure in the form of community or health facilities, measures to improve the emergency services or measures to improve and encourage nature and climate
change adaptation and mitigation in the form of green and blue infrastructure.” (Suggested changes in bold and underlined)

Additionally, the PCCWM makes further objections to omissions within the Glossary and requests two new additions as follows:

Secured by Design

Secured by Design (SBD) is the official police security initiative that is owned by the UK Police Service with the specific aim to reduce crime and help people live more safely.
The Police seeks to improve the physical security of buildings using products, such as doors, windows, locks and walling systems that meet SBD security requirements. In addition, the Police include proven crime prevention techniques and measures into the layout and landscaping of new developments, such as maximising natural surveillance and limiting excessive through movement. (Suggested changes in bold and underlined)


Through SBD, the Police work closely with builders, developers, local authorities and registered housing associations to incorporate police crime prevention standards from initial concept and design through to construction and completion. West Midlands Police have specially trained Designing Out Crime Officers (DOCOs) who offer police designing out crime and Secured by Design advice free of charge. (See About SBD)

Park Mark

The Safer Parking Scheme is a national standard for UK car parks that have low crime and measures in place to ensure the safety of people and vehicles. Each car park undergoes a rigorous assessment by specially trained police assessors and a Park Mark is awarded to each car park that achieves the challenging standards. A Park Mark is awarded to parking facilities that have met the requirements of a risk assessment conducted by the Police, meaning the operator has put in place measures that deter criminal activity and anti-social behaviour (See About The Scheme).(Suggested changes in bold and underlined)

Support

Representation ID: 1600

Received: 29/11/2024

Respondent: National Highways

COMMENT ON SUSTAINABILITY APPRAISAL.

Acknowledge receipt of document. Note that new development allocations are focused within Regeneration Areas and Centres which is likely to result in a more efficient use of land while enhancing the sustainable travel options. This is welcomed.

Comment

Representation ID: 1603

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON TRANSPORT EVIDENCE BASE AND IMPACT ASSESSMENT

Impact Assessment
Any potential sites anticipated to have an impact on the SRN are recommended to be subject to consultation with National Highways, and appropriately assessed in line with the Department for Transport (DfT) Circular 01/2022.

The cumulative impact of site allocations also needs to be assessed in line with this guidance.

Black Country Transport Modelling Report

Have reviewed 2024 modelling report published as part of the Regulation 19 consultation. Several comments to make to seek clarity:
- How have COVID-19 impacts been accounted for.
- Clarification on when NTEM is referenced what version/scenario this is.
- Clarification on the forecasting approach- only single forecast presented.
- Information on the derivation of any new parameters developed.
- Information to help understand the stability of the model outputs.

Comments also submitted to Sandwell Reg 19 Local Plan and in the process of reviewing a response note provided.

Comment

Representation ID: 1604

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

INFRASTRUCTURE DEVELOPMENT PLAN

The Infrastructure Delivery Plan (IDP) dated October 2024 acknowledges, at paragraph 7.1.2, that the response of the WMPCC, whilst not site specific, highlighted a need for more policing resources and supporting infrastructure. However, it goes on to comment that no specific physical infrastructure was identified.

The day-to-day operation of a modern police force such as WMP requires flexibility and mobility to be able to respond in an effective and efficient manner. Officers are increasingly mobile, and as such there is a reduced reliance on physical “bricks and mortar” and a greater emphasis upon infrastructure such as, but not restricted to, equipment and police vehicles.

As has previously been indicated within this submission, the planned growth within Dudley during the plan period will bring with it increased levels of crime, of all sorts, and in turn increased demands placed upon WMP. For new development to be considered truly sustainable, it must deliver necessary associated infrastructure, and within this must be provision for police infrastructure.

The basis, and support for such provision has been set out above, with the attached Appendix 3 providing a detailed breakdown of household numbers; crime figures; and increased Police infrastructure requirements, all costed out to provide the current (2023) figures, which suggest that for new residential development a figure of approximately
£128.50 per new home, on qualifying sites, would provide the necessary mitigation and ensure that appropriate levels of WMP infrastructure can be provided to assist with future policing of the development. This could be achieved either via CIL, or S106 obligations.

Comment

Representation ID: 1606

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

The PCCWM has suggested some improvements that could be made to the objectives of the plan. On examination of the SA, it is clear from Table 2.1 that the appraisal adopts a generic set of different strategic objectives. Is this entirely appropriate? Shouldn’t the SA adopt the objectives as set out in the emerging plan? Otherwise, isn’t there a risk of divergence when the objective should be the opposite?

Paragraph E1 of the Executive Summary refers to high level environmental protection whereas Paragraph E2 (correctly) identifies that the SA has to consider, and presumably balance, social, economic and environmental performance. This apparent discrepancy should be reviewed as it suggests that the environmental point of the triangle is given greater prominence in the assessment.

Comment

Representation ID: 1607

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON INFRASTRUCTURE DELIVERY PLAN

Note that the transport modelling work was not completed during its preparation and therefore, the specific infrastructure and mitigation requirements are yet to be finalised. We look forward to reviewing the finalised list once it is available.

Updates provided on some projects within the table.

Acknowledge several transport schemes to improve active travel and public transport are identified.

Comment

Representation ID: 1608

Received: 29/11/2024

Respondent: National Highways

COMMENTS ON DUTY TO COOPERATE

For any developments which have an impact on neighbouring Local Authorities (LA), National Highways advises a joined-up approach in which National Highways, Dudley MBC and the other local authorities attend joint meetings with future developers. This will ensure that the interests of all parties are protected, and a combined solution is derived.

National Highways will actively work with Dudley MBC to develop and draft a Statement of Common Ground (SoCG) to deal with any strategic cross boundary issues as the Local Plan progresses.

Object

Representation ID: 1615

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

WL objects to the Council's strategy of not meeting its housing needs within its own boundaries and instead relying on other authorities in the Housing Market Area (HMA) to accommodate the shortfall. The HMA already faces significant pressure from constrained authorities, and there is limited capacity for overspill. WL argues that Dudley should use available land, including Green Belt land, to meet its own housing needs and assist neighbouring authorities like Birmingham, Sandwell, and Wolverhampton. The failure to reach agreements on how to address unmet housing needs across the HMA suggests Dudley has not fulfilled its duty to cooperate with neighbouring councils, potentially leading to unmet housing needs and poorer housing outcomes for many residents.

Object

Representation ID: 1616

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

WL expresses concern over the Council's approach to the Local Plan, particularly the failure to address the unmet housing needs within its own boundaries and the omission of the Worcester Lane site, which could contribute significantly to housing delivery. They highlight the government's draft National Planning Policy Framework (NPPF) and the expectations for local plans, noting that the Council should ensure the plan is ready for examination and should not submit deficient plans. WL criticizes the lack of proper consideration for representations made during consultations, expressing concerns that the plan will not be thoroughly examined before submission.

WL also objects to the Council's strategy of focusing development on previously developed land and not reviewing Green Belt boundaries. They argue that this approach will lead to significant social and economic consequences for the local community and businesses, particularly given the housing shortfall. WL contends that the plan is unsound and fails to meet housing needs adequately. Their proposed solution is to allocate more land for housing, including removing land from the Green Belt where necessary.

Comment

Representation ID: 1617

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

The Vision for Dudley sets out a number of areas that the Council wish to see achieved through the delivery of the Local Plan.
These include making Dudley an attractive and desirable place to live, work and visit, having strong, inclusive resilient and
thriving communities which enhance health and social wellbeing and providing a wide range of housing that will meet people's
needs through their various life stages and is affordable to live in. We are generally supportive of the Vision in that it is
aspirational and seeks to deliver the development needs of its residents over the Plan Period. We particularly welcome the
intention to deliver a wide range of housing that will meet people's needs.

Object

Representation ID: 1618

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL objects to the omission of Worcester Lane from the Local Plan, where it was previously considered for housing in the Black Country Plan. WL argues that the site is suitable for development, addressing housing needs in Dudley and the wider Housing Market Area (HMA). They highlight that objections to the site, such as infrastructure capacity, traffic, loss of Green Belt, and environmental concerns, can be mitigated through planning processes. WL contends that releasing Green Belt land is necessary to meet housing needs, particularly when other authorities in the HMA cannot meet their own. They argue that the site’s development would provide economic benefits and contribute to affordable housing, without significant harm to the Green Belt’s function.

Comment

Representation ID: 1619

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Table 4.1 sets out the Council's strategic objectives and priorities. We note Objective 1 is the conservation and enhancement
of a natural and built environment including the strategic priority of addressing the climate and ecological emergency. We also
welcome Strategic Priority 4 of fostering economic growth and investment and Strategic Priority 6 of creating thriving
neighbourhoods by providing new and affordable homes in range of sizes, types and tenures to meet the Borough’s housing
needs. Similarly, we welcome Strategic Priority 7 that seeks to deliver the resources, infrastructure and services to support
growth.

Comment

Representation ID: 1620

Received: 29/11/2024

Respondent: Clockfields Green Space Campaign Group

Number of people: 10

Clockfields

As my representation for Regulation 19 of the Dudley Local Plan Consultation I would like to please express my full support for the designations below for the Clockfields green space and woodland:

1) Land at Clockfields SLINC

2) Tree Preservation Order TPO/0042/AMB

3) Recognition of central designated public open space as Amenity space

I would also like to please request that the council reconsiders the decision for a possible Local Green Space designation at the site as submitted during the Regulation 18 consultation and fully support any additional protection measures and policies that could further protect the site for the benefit of the local community and future generations such as Site of Interest for Nature Conservation (SINC).

You may also want to request that the currently unmarked path from the end of of Culverhouse
Drive to the canal be designated a formal Public Right of Way.

Regulation 19 of the Dudley Local Plan is under consultation, sadly our request under Regulation
18 for 'Local Green Space' (equivalent to green belt protection) last year was turned down but we can still appeal that decision. The revised LGS request was downscaled from all 4 green areas and wooded areas to just the middle area of green space and adjacent patches at the end of Culverhouse Drive (as it needs to be one area as such).
Below is a summary and details of each of the 4 parcels of green space and woodland.

1. Mature woodland which has existed since well before the estate was built and covered by Woodland TPO (TPO/0042/AMB) from 2011. Generally mature woodland is protected from development by Dudley Council

2. Same as above, the strip between the estate and Brettell Lane, mature woodland covered by the TPO.

3. The area of Public Open Space designated by Wrekin Homes as a condition of building the estate. The trees are covered individually under the TPO. It is recognised as publicly accessible amenity space in the council green space assessments. Amenity spaces and open green spaces like this aren't automatically protected from development unless they have Village Green or Local Green Space designation (the latter is the newer one).
4. Land planted as part of the Black Country Urban (Millennium) Forest which includes private open space on the edges (Planning application P00/51751) due to land stability issues. This has both SLINC (Site of Local Interest for Nature Conservation) status and the Woodland Tree Preservation Order to supposedly cover all trees of any age and size. Potential upgrades would be SINC (Site of Interest for Nature Conservation) which would offer further
protection.

I've also included a map that might be of interest which is an overlay of the estate as it is now over an aerial photo from 1963.

You can see the maps in more detail at the Council Historic Maps site:
https://maps.dudley.gov.uk/custom/historicl.asp

Object

Representation ID: 1623

Received: 08/01/2025

Respondent: Heyfield Developments

Agent: Harris Lamb

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

We do not consider that the Council has taken the appropriate measures to fulfil the Duty to Co-operate. We consider that discussions should be reopened with adjoining authorities, including South Staffordshire, to allow for the land required to meet Dudley’s development needs to be identified and committed. These discussions will need to be in the context of the unmet need across the conurbation and the neighbouring authorities should be encouraged to release more land to assist.

The Duty to Co-operate relates to the production of the Dudley Local Plan, where as the Duty to Co-operate Statement October 2024 seems to focus on the process taken through the Black Country Core Strategy review. Separate to the fact that the discussions prior to the demise of the Black Country Plan did not relate to the Dudley Local Plan, the position has materially changed since the demise of the Black Country Plan and over 2 years has passed. The discussions around the Black Country Plan did not resolve the unmet housing need and allot of further work was needed to deal with substantial demand for land to assist in meeting the unmet need arising.

The split of the four Black Country Authorities also notably increased the onus on the Duty to Co-operate. For Dudley MBC, it meant new discussions were needed with the neighbouring authorities previous spoken with and it required a new look at the interrelationship with the three other Black County Authorities, a matter previously enveloped by producing a joint plan. For Dudley, the break-up of the Black Country plan may have meant less pressure through its own plan to release land to meet its needs, but it did not remove the need arising from the adjoining Black Country authorities nor reduce the amount of land available within Dudley MBC to assist these authorities.

Since the start of the Dudley Local Plan, little in the way of co-operation with adjoining authorities appears to have happened. The challenges presented by the substantial unmet need were clear at the start of the preparation of the Dudley Local Plan and we would have expected co-operation with adjoining authorities to be at the heart of the plan making process to address these issues. However, this does not appear to have happened.
We now have a pre-submission plan where we do not know where the unmet need from Dudley will go nor to what extent Dudley MBC are going to assist the other Black Country Authorities with their unmet need.

Furthermore, rather than these matters being resolved, the Duty to Cooperate Statement sets out what measures are going to take, which seems back to front from our perspective, particularly given the scale of the issues here.
The reality is that the unmet need figures for housing and employment are significant in this location. For this to be met requires a group effort. More needs to be done to work with the authorities affected by this (both in terms of those authorities where the unmet need arises and those authorities with the ability to assist in meeting the unmet need).

Object

Representation ID: 1626

Received: 16/11/2024

Respondent: Mrs M Wylde

Number of people: 2

Agent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

The clients assert that Dudley Council is not promoting environmentally sustainable development in its emerging Local Plan Review, and its approach conflicts with key sustainability principles outlined in the Revised NPPF (December 2023). They argue that there is a clear limit to how much new development can be accommodated in the Halesowen area, which is already overloaded with unsustainable development patterns. This overdevelopment is harming the local environment and negatively impacting the health and well-being of residents. The clients express concern about the spatial imbalance in development across the Dudley Borough, warning that the increasing trend of urban cramming is damaging both the environmental quality and character of the area, as well as the health of its population.

Object

Representation ID: 1628

Received: 16/11/2024

Respondent: Mrs Karen Dunham

Number of people: 2

Agent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

The clients assert that Dudley Council is not promoting environmentally sustainable development in its emerging Local Plan Review, and its approach conflicts with key sustainability principles outlined in the Revised NPPF (December 2023). They argue that there is a clear limit to how much new development can be accommodated in the Halesowen area, which is already overloaded with unsustainable development patterns. This overdevelopment is harming the local environment and negatively impacting the health and well-being of residents. The clients express concern about the spatial imbalance in development across the Dudley Borough, warning that the increasing trend of urban cramming is damaging both the environmental quality and character of the area, as well as the health of its population.