Comment

Representation ID: 925

Received: 21/11/2024

Respondent: Dennis R Whittaker

The aim must be to achieve the right balance between Housing land, Employment land and land for other uses. I am concerned that, in the DLP proposals, some present Employment land has been allocated for Housing. In the case of some such sites, I question the wisdom and logic. People need employment in order to buy or rent Houses - and, to minimise journey times, not too far away.
Regarding the 699 Houses to be "exported" under Duty to Cooperate Agreement - surely this will work both ways with other Local Authorities wanting to export to Dudley Borough?

Object

Representation ID: 1032

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In order to meet its own needs, we consider that Dudley should seek to accommodate as much housing as possible within its own administrative boundary, including through maximising densities. Dudley should also consider whether focussed Green Belt release could assist in accommodating need.
Sandwell considers Policy DLP1to be unsound. Although Dudley have looked to utilise previously developed sites within the urban area and to increase densities, the plan doesn’t clearly set out why the Green Belt hasn’t been reviewed, especially as there are sites, previously identified as suitable, that would enable the council to meet its need in full.

Comment

Representation ID: 1061

Received: 28/11/2024

Respondent: Hagley Parish Council

Hagley Parish Council are concerned that Dudley MBC cannot quite meeting all its development needs, having a shortage of land for 699 houses. Welcoming the decision not to review Green Belt boundaries, recalling that a previous consultation proposed to allocate land along Worcester Lane, Pedmore for housing.
Dudley should also not look to meeting its land supply deficit in Wyre Forest District, in so far as that might
involve an increase in traffic on A456 through Hagley (to meet needs arising in Halesowen), as A456 is
already used beyond its capacity at peak times and would not be able to accommodate housing on the
scale allegedly required, unless there were very substantial highway improvements. Such improvements
would have to be on such as a large scale as to render the housing development financially unviable.

Object

Representation ID: 1062

Received: 28/11/2024

Respondent: Bloor Homes

Agent: Harris Lamb

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bloor objects to Policy DLP1, arguing that it is not positively prepared, effective, or consistent with national policy. The policy’s approach to meeting housing needs in Dudley will leave a significant portion of the housing demand unmet, resulting in higher housing costs, increased overcrowding, and more people living in unsuitable housing. Beyond the social costs, Bloor emphasizes the potential economic impacts, particularly if the working-age population cannot find housing in the Borough. This could lead to outward migration, an aging population, and a reduced workforce, which would negatively affect the delivery of services.

Bloor argues that the approach in the plan is unsound and calls for Dudley to work with neighboring authorities in the Housing Market Area (HMA) to find a clear, tangible solution for addressing unmet housing needs. Without a formal, signed agreement between the authorities outlining how the unmet needs will be distributed, Bloor believes there is no realistic prospect of fully meeting housing demand in the region.
Bloor contends that Dudley should first exhaust all potential land within its boundaries, including Green Belt land, before looking to neighbouring areas. Failure to do so could result in significant adverse effects, such as local residents being unable to live in the Borough, economic issues from a shortage of working-age residents, and worsening housing conditions due to a lack of affordable housing. Bloor argues that exceptional circumstances exist for a review of the Green Belt boundaries to ensure sufficient housing delivery and avoid these negative impacts.

Comment

Representation ID: 1065

Received: 28/11/2024

Respondent: CPRE Worcestershire

Agent: CPRE Worcestershire

Concerned that Dudley MBC is putting forward a plan that fails to meet its objectively assessed development needs in full, though it manages to come fairly close to that.This failure makes the plan unsound at present. Wherever the deficit is met, it should not be in Bromsgrove District. As it is not an appropiate destination for exported housing (or employment land).

Nearly all undeveloped land in Bromsgrove District is designated as Green Belt, which serves to maintain the separation between Birmingham, the Black Country, and the town of Bromsgrove, as well as the large commuter villages in the area, such as Hagley, Catshill, Barnt Green, Alvechurch, and

Comment

Representation ID: 1066

Received: 28/11/2024

Respondent: CPRE Worcestershire

Agent: CPRE Worcestershire

CPRE Worcestershire raise concerns that Dudley MBC's plan does not fully meet its objectively assessed development needs, rendering the plan unsound. While to comes close, there remains a deficit in housing provision that needs to be addressed. CPRE Highlights the Lickey Hills and Clent Hills, arguing that expansion into this area would not be desirable.

Dudley should seek statements of common ground with other authorities (such as Telford and Wrekin) by which they would provide development land to meet Dudley's deficit,

Object

Representation ID: 1068

Received: 28/11/2024

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

1.Local Housing Need: The Council has not assessed whether a housing requirement greater than the LHN is justified. Large reliance on windfall sites.
2 Changes to the Standard Method and NPPF: The Council does not acknowledge the draft NPPF and the changes in national policy on plan-making.
3 GBBCHMA Unmet Needs: The DLP fails to acknowledge the unmet housing need arising from the Greater Birmingham and Black Country Housing Market Area [GBBCHMA] when seeking to export Dudley’s housing shortfall.
4 Duty to Cooperate: The Duty to Cooperate has not been fulfilled and the unmet housing need identified has been deferred rather than dealt with, contrary to NPPF
paragraph 35(c).
5 Sustainability Appraisal: The Draft Sustainability Appraisal fails to consider all of the options available to meet the LHN as well as the GBBCHMA’s unmet need, and therefore would not be justified as per NPPF paragraph 35(b).
6 The Deliverability of Brownfield Land: The proposed supply of brownfield land and windfall sites is an unrealistic and unviable strategy. In reality, the shortfall of
housing land is greater than what has been stated within the DLP.
7 Transitional Arrangements of the Draft NPPF: Based on the current arrangements, it is considered unlikely that the DLP will proceed through examination.
8 Exceptional Circumstances and Green Belt Release: The DLP does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for
housing. The DLP does not recognise that exceptional circumstances for the release of land from the Green Belt exist.

Object

Representation ID: 1075

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Barberry have significant concerns about the proposed development strategy and specifically around how the Council intends to meet its housing needs over the Plan Period. We also have similar concerns in respect of how its employment land needs will be met and we set out our detailed comments on these points below.

The Council are not claiming that there are exceptional circumstances that warrant divergence away from the use of the standard method. As such, it must be concluded that the housing requirement is 11,169 dwellings. However, the Plan identifies a shortfall of 699 homes that are required but where sufficient capacity within the Borough to accommodate has not yet been identified.

The spatial option that the Council have decided to pursue seeks to focus on meeting the development needs of the Council on previously developed sites within the urban area, use of low quality open space and through duty to cooperate discussions meaning that the Council will be looking to the other authorities in the HMA to accommodate its unmet need of 699 dwellings. Barberry object to this approach and do not consider it sound.

If the 699 dwellings are to be accommodated in adjoining authorities this would likely result in those authorities immediately adjoining Dudley, which also have significant areas of Green Belt, having to release land from their Green Belt in order to meet Dudley’s needs. If land has to be released from the Green Belt in order to meet the development needs it is Barberry’s view that Dudley should be looking at opportunities within its own administrative area first, including land in its Green Belt in order to accommodate this, before looking to its adjoining neighbours. If adjoining authorities take the same viewpoint as Dudley and decide that they also do not need to release land from the Green Belt, housing needs arising from Dudley and across the HMA are not going to be met.

The Plan does not elaborate on the Council’s decision not to release land from the Green Belt to meet its needs particularly when the Plan highlights that there is a shortfall of what is needed against what land is available to accommodate this need. Barberry consider this to be a short-sighted approach particularly when land is available albeit it is in the Green Belt, which could help meet the Council's housing needs over the Plan Period. This point is particularly pertinent when under the Black Country Plan Preferred Options version, the Council had proposed to release land from the Green Belt to meet the Council's needs as well as the unmet needs arising in the wider Black Country authorities. Again, the Plan does not provide clear or sufficient justification for the decision of the Council not to release land from the Green Belt nor why this unmet need should be met elsewhere when there is sufficient suitable land available within the Borough to meet these needs. Furthermore, whilst the current Framework does not require Green Belt to be reviewed, it does state that it can still be reviewed in exceptional circumstances. Barberry contend that exceptional circumstances exist that warrant a review of the Green Belt.

The land at Swindon Road, Wall Health, Kingswinford was identified as a draft allocation in the Black Country Plan Preferred Options as a strategic housing site capable of accommodating 533 dwellings. Clearly at some point, the Council considered that the Site was suitable to accommodate residential development sufficient for it to be identified as a draft allocation. The Site was considered suitable and deliverable and Barberry remain of the view that it should be included as a draft allocation in the Plan. In allocating the land at Swindon Road, Wall Heath, it could potentially reduce the shortfall in housing that is required but unable to be currently accommodated in the Borough leaving only a further 166 dwellings to be found on other sites in Dudley.

In addition to the shortfall in housing land that the Borough Council is currently unable to accommodate there is also a shortfall in the amount of employment land that is needed but which sufficient land has not been identified in order to accommodate the employment requirements going forward. The Council is, therefore, looking to accommodate its housing and employment needs outside of its administrative area via agreeing with adjoining authorities for them to make land available to meet Dudley’s needs. Barberry do not consider this to be a sound approach for similar reasons as to those set out above in respect of meeting its housing needs. Barberry contend that Dudley has suitable land available within its own administrative area albeit it is in the Green Belt and that the Council should be considering the suitability of this land for development first rather than asking its neighbouring authorities to meet its needs and potentially to release land from its Green Belt in order to do so.

Rep details shortfalls in neighbouring LAs. Dudley should seek to meet its own housing need.

Barberry consider policy DLP1 unsound on the basis that it is not positively prepared, not effective and not consistent with national policy. As drafted, significant housing need will go unmet leading to a wide range of social and economic problems associated with the lack of suitable and affordable housing for residents of the Borough. Similarly, the failure to address the shortfall in provision of housing at the HMA wide level will only add to those significant housing pressures that many in the conurbation already face.

Comment

Representation ID: 1109

Received: 29/11/2024

Respondent: Mike Wood

for Kingswinford and South Staffordshire.
I agree that this plan should be submitted to the Planning Inspector as it recognises the hard work that has gone into
shaping this plan, and that it meets all reasonable projections for the borough’s medium term housing need.
I fully support this plan. I hope that the Inspector considers it quickly and that Government respects the
democratically elected local authority’s proposals.

Object

Representation ID: 1138

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The fundamental purposes of a strategic policy of this nature is to ensure that development needs, for housing and other activities, are fully and properly identified and then met. Policy DLP1 does not do this. Our representations elsewhere (principally in relation to Policy DLP10 but also in respect of the emerging new NPPF and the mandating of a new Standard Method for calculating Local Housing Need as well as failings in the Duty to Co-operate) sets out clearly why the number of houses being planned for (10,470) will be insufficient, by some margin, to meet local needs and even then, the approach set out within the plan to meet this inadequate housing requirement, will fail to even deliver this amount of housing. The level of employment land proposed is also woefully short of need.

Policy DLP1 – and the wider provisions of the emerging DLP – are inconsistent with delivering this Vision, Objectives and Strategic Priorities.

Failing to set out a sound development strategy is a fundamental flaw of this plan. This is a straightforward simple failing of this plan. It sets the context for the case made throughout these representations that Dudley should plan to meet its housing need (and more to allow some flexibility to support delivery and choice of housing). It should plan for a strategy which has evidence that it is likely to succeed, and that part of that approach needs to involve more deliverable allocations, including by necessity greenfield and Green Belt sites. The draft DLP fails, emphatically, to do this.

Environmental considerations are part of the overall planning balancing exercise and can sometimes compete with delivering growth however as drafted, the DLP gets this balance totally wrong. The plan states that to accommodate future growth, locations that are both sustainable and deliverable have been identified for development, at levels and in locations that do not breach the environmental capacity of the area. The plan has not however demonstrated the environmental capacity, nor has it identified the deliverability.

A strategy ‘Growth Option’ which is described as maximising growth in the urban area and making use of brownfield sites where available and most importantly deliverable can be appropriate, but the extent to which this is relied upon in the draft DLP is fanciful, learns no lessons from plans of the past, fails to fully acknowledge the challenges to delivery in such a way and will miss the delivery of much needed housing again for another generation. A much more deliverable, balanced identification of site and development options which promote delivery is required if development needs are to be met.

Overreliance on brownfield land was fully acknowledged in the Regulation 18 consultation draft of the BCCS Review in 2021, when the Black Country Authorities were working collaboratively on a Review of the well acknowledged failed BCCS.

To meet development needs there is a requirement for a more balanced strategy and one which also includes for more deliverable and needed greenfield sites and assesses and reviews the Green Belt to help identify potential areas of growth in the real context of a significant deficit in the supply of brownfield land within the urban area. The position whereby no Green Belt release is proposed has been arrived at for political rather than planning reasons. There is scant evidence that proper consideration has been given or judgement exercised from a planning perspective as to whether there might be opportunities within the Green Belt better to meet the Borough’s needs. Evidence as to why the full need cannot be met is lacking. This shortcoming is amplified by a lack of any clear evidence at this stage as to the extent to which the Council have, or are likely to, engage with neighbours under the Duty to Cooperate, or how fruitful any such engagement might be.

Greenfield and Green Belt sites should be allocated to help meet the need and boost deliverability. Policy DLP1 should acknowledge and accommodate this, and consequential changes should be made throughout the DLP (e.g., to Table 5.1, Policy DLP2, Policy DLP10, and elsewhere) to reflect it and allow for a contribution to be made by such sites, rather than excluding them entirely.

This is a deep concern and point of objection to the Plan which was also raised at the Regulation 18 consultation stage where the plan similarly identified an exclusively brownfield urban supply even further short of need. Rather than redressing the issue by identifying a greater supply of more deliverable, balanced range of sites, the Council have merely doubled down on this strategy, placing an even greater reliance on the urban area, identifying what can only be described as a theoretical urban capacity. In the absence of evidence on deliverability, including market and technical deliverability, the plan strategy is mere folly.

Object

Representation ID: 1155

Received: 29/10/2024

Respondent: St Modwen Homes

Agent: RPS

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

RPS objects to the 10,470 total plan requirement figure. Not least because this falls short of the local housing need for 11,169 homes as calculated by the Standard Method (657 dwellings per annum), and the resultant shortfall of 699 homes. The approach by the Council to deviate from the derived SM figure, will not address the chronic need for homes in the Borough and therefore will not deliver one of the strategic objectives of the Plan.
Based on the draft NPPF 2024, there is a requirement for 1,594 dwellings per annum in Dudley. Given the Standard Method is the minimum starting point, RPS would suggest an uplift of 138% against the current planned requirement figure be provided to assist with addressing the future housing need in the Borough.
The draft Plan would result in a shortfall of between 13,228 and 16,628 dwellings across the new Plan-period, which is a significant shortfall based on the Government’s new standard method.

Object

Representation ID: 1157

Received: 20/11/2024

Respondent: Wood Abbey

Agent: NCL Development

Legally compliant? No

Sound? No

Duty to co-operate? No

These representations are made on behalf of Wood Abbey in relation to land interests at Pedmore Hall Farm, Pedmore Lane, Dudley. The site at Pedmore Hall Farm (the Site), shown by the red line boundary attached as Appendix 1, has been promoted for residential development through the Draft Black Country Plan 2039 (Regulation 18) Consultation October
2021, and at the Draft Plan (Regulation 18) of the Dudley Local Plan in December 2023.


The Site extends to 4. 74 hectares and is capable of accommodating circa 75 homes with the potential for up to 1.5 hectares of the Site made available for publicly accessible open space. An indicative layout for the site is attached as Appendix 2.

In our previous representations on the Draft Black Country Plan and Dudley Draft Local Plan we have demonstrated how development of the Site would deliver much needed land for housing including affordable and family homes to meet the defined housing needs of the Borough, which are currently not met by the proposed strategy and policies of the emerging Dudley Local Plan.

We have positively engaged with Dudley Council throughout the Plan making process with the aim to support the delivery of the sustainable economic and housing growth of the area and contribute to meeting the needs of local communities.

We have demonstrated that there are exceptional circumstances to review the Green Belt and that amendment to the Green Belt boundary and allocation of the Site for residential development would not harm the purposes of the Green Belt.

We continue to support the principle of preparing a Local Plan for Dudley but we consider that the Plan as presented is unsound. We have set out the basis for this on pages 2 to 7, as follows.

Failure to meet area's objectively assessed needs


The Plan fails to provide a sufficient amount and variety of land to meet the housing and employment needs of the Borough.

Dudley's local housing need for the plan period, 2024-2041, is 11,169 net homes. The current Plan has identified sites to deliver 10,470 new homes leaving a shortfall of 699 dwellings in the Borough.

Further to the shortfall in supply of land to meet housing needs the Plan does not identify sufficient land to meet employment requirements.

The Borough has an employment need for 72 hectares of land. As a result of the loss of employment land to alternative uses the overall employment land requirement increases from
72ha to 98ha (an increase of 26ha). The increased requirement for new employment land is as a result of the Plan's reliance on the redevelopment of employment land to provide a large proportion of the supply of land for the 10,470 homes.

The Plan has identified 22.62 hectares of land for employment uses resulting in a shortfall of at least 49.38 hectares. When taking into account the loss of employment land this shortfall increases to 75.38 hectares.

This shortfall is proposed to be addressed through the Duty to Cooperate with a number of local authorities contributing to the needs of the Borough. Dudley is not proposing to contribute to address the unmet needs of its neighbours including Birmingham, which has a significant shortfall of land to meet its housing need due to its constrained administrative boundaries.

The provision of housing to meet Dudley's shortfall is predicated on progress with the Local Plans of those identified neighbouring authorities under the Duty to Cooperate, see Dudley Local Plan Duty to Co-operate Statement October 2023. We consider that there is significant uncertainty with progress on those Local Plans and as such the housing contributions should not be relied upon to meet Dudley's needs.

The Inspector for the Shropshire Local Plan has recently, October 2024, written to Shropshire Council stating they have, "significant concerns about the soundness of the Plan in respect of a number of areas." We consider that the potential contribution from Shropshire cannot be relied upon and therefore the 431 homes should be removed from the potential supply.

Lichfield District Council withdrew their Plan in October 2023 and are commencing the preparation of a new Plan that has only reached issues and options stage. Owing to the changes in national policy, as discussed below, we consider that any contributions cannot be relied upon until the full implications of the national changes are assessed through Lichfield's Local Plan preparation. This would further reduce assumed supply by a further 68 homes.

South Staffordshire has reduced their contribution to the Greater Birmingham & Black Country
HMA from 4,000 to 640 homes, as set out in the recently published Duty to Cooperate Topic

Paper (April 2024 ). This would significantly reduce any potential supply to Dudley further increasing the shortfall for the Borough.

Telford & Wrekin Council have updated their position on their Local Plan in November 2024. They have recognised the implications arising from the Government's proposed changes to the National Planning Policy Framework (NPPF) including the transitional arrangements and that the Council will be aligning their Local Plan with this new framework. There is no confirmed timetable and no defined contribution toward Dudley's unmet need.


Undeliverable and unjustified strategy


The current strategy of the Plan focuses on land within the urban area with 97% of development on brownfield land.

As set out above this strategy fails to provide sufficient land to meet current needs and would be wholly insufficient to meet the Government's national policy objectives to address the national housing crisis and the proposed significant increase in housing numbers for Dudley and neighbouring authorities.

There has been a consistent failure to deliver the homes that are required to meet the needs in the Borough. Over the past 5 years only 532 homes have been delivered per annum, which is significantly short of the completions required to meet current objectively assessed needs. Factoring in the forthcoming changes necessary to address the national housing crisis would see under-delivery of 1,062 per annum against current/ historic performance.

This under-delivery coincides with a continued focus on developing the urban area and employment land.

In order to achieve the strategy and deliver sufficient previously developed land a target of redeveloping 12 hectares of employment land per annum (page 11 Dudley MBC AMR
2023/24) is required. Over the past 5 years the authority has seen an average of only 4.7 hectares per annum delivered. On the basis of a longer term historic trend of delivery, dating from 2012, the average falls to 3.8 hectares.

The strategy has an over reliance on redevelopment of complex employment sites and brownfield land where there has been a consistent failure to deliver.

The focus on largescale regeneration areas to deliver housing needs has also failed to achieve a consistent supply of land. One of the largest single contributors to supply is the Brierley Hill Strategic Centre, accounting for 1546 new homes over the Plan period. This accounts for
14.7% of the total housing supply in the current Plan. In the period from adoption of the AAP

(2011) for the area, up to the latest monitoring return 2023/24, there has been a cumulative total of 507 new residential units delivered within the Centre (page 49 Dudley MBC AMR
2023/24). This equates to 39 new homes per year in the period.


There is no evidence to suggest that a step change in the rate of delivery can be achieved in Brierley Hill. Projecting this modest delivery rate over the new Plan period (2024/25 - 2040/41) would equate to only 663 homes delivered, less than half the supply required in the Local Plan.

The Metro extension to Brierley Hill is referenced as an important catalyst, however this project was shelved in Summer 2024 due to cost. It is recognised that funding has been allocated in the Autumn Budget 2024 for the Metro project but there is no certainty over a timetable for the project and how continued cost increases and delivery challenges are addressed.

We consider that the reliance on brownfield land including redeveloping existing employment sites will not deliver the number of homes to meet current needs.



Failure to consider reasonable alternatives


There is currently 1,770 ha of land that has not been assessed in preparing the Plan and the contribution that it can make to meeting the Borough's objectively assessed needs.

In preparing the Plan the Council has failed to assess the contribution that sustainable sites in the Green Belt can make.

We consider that there are exceptional circumstances, this being the housing and economic development needs of the Borough and the national housing crisis, to justify the review of the Green Belt and alteration of boundaries to accommodate sustainable patterns of development.

Land in the Green Belt, which is well related to the urban area including the site at Pedmore Hall Farm, would positively contribute to the overall vision and strategy to deliver sustainable patterns of development and support sustainable economic and housing growth meeting the needs of local communities and businesses.

We consider that the Green Belt boundary can be amended and sites, including land at Pedmore Hall Farm, allocated for development without undermining the purposes of the Green Belt across the area of the Plan as a whole.

We also consider that where such negative impacts arise the development can mitigate these impacts including defining boundaries clearly, using physical features that are readily recognisable and likely to be permanent including established landscape features.

The benefits of such development would also outweigh any harms that could be considered to arise. This includes the significant need for new homes including affordable housing.

The Site extends to 4. 74 hectares and is capable of accommodating circa 75 homes with the potential for up to 1.5 hectares of the Site made available for publicly accessible open space. An indicative layout for the site is attached as Appendix 2.

The Site would deliver a sustainable pattern of development by extending the existing community of Pedmore with a new sustainable residential development. The Site is well located to provide access to services and facilities to meet the day to day needs of future residents and enable travel by sustainable transport options to connect to health, education, jobs and leisure.

The allocation of the Site for residential development would also result in the redevelopment of existing buildings and areas of hardstanding making more effective use of land and removal of visually detracting features from the landscape.

There would also be opportunities to create new open space increasing biodiversity and ecological networks that positively contribute to delivering ecological opportunities for
the Pedmore, Wychbury & Lutley area and improvements to the quality of remaining Green
Belt. The Site's location would also allow for improvements to the understanding and appreciation of the Wychbury Hill Fort.

The Site is demonstrated to be suitable, available and achievable for development and could contribute to the five year housing supply as a deliverable site.

The Site represents a suitable location for residential development due to its location and proximity to services and facilities.

The Site is considered available for development demonstrated by the evidence submitted to date and response to the Call for Sites. The Site is in single ownership, and the landowner has expressed intention to sell, with a land promoter appointed demonstrating that it is available for development now.

Residential development on the Site is achievable as there are no known impediments to development and no foreseen extraordinary development costs or constraints that would impact on the economic viability of the Site.

The Site is also considered to be deliverable, as it is available now, offers a suitable location for development now, and there is a realistic prospect that housing will be delivered on the site within five years.



Conclusion


In summary, we consider that the Plan will not meet the tests of soundness as set out in
Paragraph 35 (NPPF December 2023), for the following reasons:


We do not consider that the Plan has been positively prepared. The Plan and specifically Policy DLP1 does not provide a strategy which, as a minimum, seeks to meet the area's objectively assessed needs. The Plan fails to identify sufficient land to meet its housing needs and there is no realistic strategy to address this. It is unable to rely on neighbouring authorities to accommodate the needs that cannot be met.

We do not consider that the Plan is justified. The Plan and associated sustainability appraisal has not taken into account reasonable alternatives as it has failed to assess the contribution that Green Belt land can make to meeting the needs in the Borough. There are exceptional circumstances including local housing needs and the national housing crisis. Land in the Green Belt, such as the Site at Pedmore Hall Farm, would constitute a sustainable pattern of development and its allocation and removal from the Green Belt would not undermine the primary purpose of the Green Belt.

We do not consider that the Plan is effective. The Plan and specifically Policy DLP1 and Policy DLP10 is not deliverable over the plan period as it relies on development of brownfield land including existing employment areas where there has been a consistent failure to deliver housing at the numbers required over the past 15 years. There is no evidence to demonstrate that this trend can be improved.

We do not consider that the Plan is consistent with national policy. The Plan and specifically Policy DLP1 and Policy DLP10 fail to enable the delivery of sustainable development. It does not identify a sufficient amount and variety of land where it is needed to meet local needs. It fails to respond to the national housing crisis and Government's stated changes to national planning policy, which will include a significant increase in the housing requirement for local authorities including Dudley. Under the transitional arrangements the Plan will need to be considered against the new NPPF.

Object

Representation ID: 1163

Received: 27/11/2024

Respondent: Mrs Eleanor Lovett

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The Council is failing to plan for sufficient housing to meet the Borough's needs, contrary to the
requirements of national policy, or good practice for plan-making. The Government advocates a
plan-led approach to development, but the Council has not done so through this publication draft
Plan. Relying on neighbouring authorities is inappropriate in a context of significant unmet housing
needs elsewhere, with limited options as to how these can be met. The Council should, at least, be
planning through this Local Plan to deliver an appropriate level of housing, in order to ensure that
local housing needs will be met.

Object

Representation ID: 1183

Received: 28/11/2024

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DLP1 states that to deliver sustainable growth the plan will need to deliver the development of at
least 22.6ha employment land, this represents a reduction in the minimum level of employment land to
be delivered from the Regulation 18 consultation version of the Plan. The policy states the strategy seeks
to deliver sustainable patterns of development with growth focused on the borough’s centres and
regeneration corridors.
3.2 The focus of further growth and development within the borough’s centres and regeneration corridors is
supported. However, the proposed level of delivery of employment land within the borough is considered
insufficient, particularly in light of the reduction in the proposed delivery of employment land from the
previous consultation version of the document. This is considered further below, within the context of
policy DLP18.

Object

Representation ID: 1209

Received: 28/11/2024

Respondent: Clowes Development LTD

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

The Council are, however, not planning so ‘significantly boost’ their supply of housing by only planning to meet the minimum requirements. There is also no identified buffer included, so that there would still be delivery of housing to meet target should a site fail to deliver.
None of the Options for delivery of housing referred to increased or higher growth numbers and therefore all reasonable alternatives have not been assessed in the Sustainability Appraisal (September 2024).
It is therefore considered that the Plan should include for a 5% or 10% uplift on housing figures, which will allow the Council to plan for delivery of growth in accordance with the spatial strategy, in sustainable locations and have a buffer should any sites not deliver as expected or become stalled for any reason.
Due to the revised NPPF expected to be delivered in December 2024, it appears prudent to revisit the identification of land for housing growth and seek to identify additional land for housing. As drafted, it appears that the Plan may not be sound as it is unlikely to be consistent with national policy and the revised standard method and therefore cannot be seen to have been positively prepared.
There is no clear approach to how the Council’s unmet need will be met in neighbouring authorities, and with other neighbouring authorities declaring unmet need that they are looking to Dudley to assist with, the Council appear to not be addressing their unmet need through the Duty to Co-Operate and indeed are not fulfilling the Duty to Co-Operate duty.

Employment
Similarly, the employment target set out in the Plan and chosen spatial growth option 2 (meeting all need in the urban areas and via DtC contributions). But neither option considered an increased or higher amount of employment land and therefore all reasonable alternatives have not been assessed in the Sustainability Appraisal (September 2024).
it is not considered that the Duty to Co-Operate has established 50ha of land which can be delivered elsewhere to meet Dudley’s needs. If this is the case, then the Plan is unsound as it will not meet the area’s needs and is therefore not positively prepared.
With reference to both housing and employment land, it is not considered that all reasonable alternatives have been assessed for meeting Dudley’s growth needs, and the Council have not met their Duty to Co-Operate requirement, or clearly identified where unmet needs are going to be delivered in neighbouring authorities.

Comment

Representation ID: 1228

Received: 29/11/2024

Respondent: West Midlands Housing Association Planning Consortium (WMHAPC)

Agent: Tetlow King Planning

Draft Policy DP1 proposes a housing requirement of at least 10,470 new homes over the Plan period. However, paragraph 5.12 on page 72 of the Draft Local Plan identifies a LHN for Dudley of 11,169 homes across the same period. This means the emerging Local Plan currently falls short of meeting its identified LHN by 699 homes, based on the proposed housing requirement.
It is also imperative to note that under the transitional arrangements proposed by the government, local plans that do not reach Regulation 19 stage by the time that the new NPPF is enacted would be required to take full account of the new NPPF policies, in addition to the updated LHN figures. Where a Local Plan has reached Regulation 19 stage, the annual housing requirement in the plan will be compared against the updated LHN for the authority area. If the emerging annual housing requirement in the draft Local Plan is more than 200 dwellings per annum below the updated LHN, the LPA will be required to revise its emerging Local Plan to reflect the new NPPF and the updated LHN and submit the plan for Examination within 18 months.
As part of the NPPF consultation, the Government released a spreadsheet containing the outcome of the revised LHN standard method for each authority. The proposed updated LHN for Dudley is 1,594 dpa. This figure is not considered in the Issues and Option consultation material. The consultation material proposes a housing requirement of 10,470 homes over the 17-year period between 2024 and 2041, equating to 616 dpa which leaves a difference that is far in excess of the 200-dwelling buffer set out in the proposed transitional arrangements. If the NPPF and Standard Method proposals are implemented by the Government, Dudley will need to produce a replacement Regulation 19 local plan to accord with the new policies in the new Framework and Standard Method before proceeding to examination within 18 months.
The Council should take a cautious and collaborative approach to strategic policies in relation to housing needs, supply and the Green Belt. It is essential to confirm whether the neighbouring authorities of the Greater Birmingham and Black Country Housing Market Area’s (“HMA”) have the capacity to accommodate Dudley’s housing need shortfall before progressing with a Local Plan which could compromise the ability to meet housing needs across the wider region.

Object

Representation ID: 1248

Received: 29/11/2024

Respondent: Praxis Group

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DLP1 is criticized for not fully addressing the Housing Requirement and for failing to support neighbouring authorities (Wolverhampton, Sandwell, Birmingham) with unmet needs. The Duty to Cooperate is seen as insufficient, especially after the collapse of the Black Country Core Strategy.

The Housing Requirement is based on the current Standard Method, expected to increase, and if Dudley cannot avoid this, the strategy and Duty to Cooperate will need revisiting. The client, with land in South Staffordshire, offers to collaborate with Dudley and South Staffordshire to address the additional need.

The strategy's reliance on urban capacity and increased density assumptions is questioned, given stricter design requirements. To meet housing goals, design standards need adjustment or density assumptions should be reduced.

The Duty to Cooperate is deemed inadequate. The Council must restart discussions with neighbouring authorities, including South Staffordshire, and work with other Black Country authorities to address unmet housing needs.

Object

Representation ID: 1253

Received: 27/11/2024

Respondent: St Phillips Land Limited

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

St Philips objects to draft Policy DLP1 on the same basis as raised within St Philip’s regulation 18 representations. Although the housing requirement has been amended from 10,876 dwellings to 10,470 dwellings in the plan period against a Local Housing Need (“LHN”) of 11,169, it still leaves a shortfall of 699 dwellings which is to be exported through Duty to Co-operate.

Paragraph 69 requires that the Council needs to ensure that additional housing land should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability to deliver specific deliverable sites for the first five years of the plan period and deliverable sites of broad locations to meet needs for years 6-10 and 11-15 of the plan periods.

The Council has not done this and consequently Policy DLP1 in relation to housing land supply is not sound.
Proposed NPPF is not acknowledged in the plan.
In this regard, St Philips considers that the DLP’s approach through draft Policy DLP1 is flawed on several grounds, and these are summarised below:

1 Local Housing Need: The Council has not assessed whether a housing requirement greater than the LHN is justified.
2 Changes to the Standard Method and NPPF: The Council does not acknowledge the draft NPPF and the changes in national policy on plan-making.
3 GBBCHMA Unmet Needs: The DLP fails to acknowledge the unmet housing need arising from the Greater Birmingham and Black Country Housing Market Area [GBBCHMA] when seeking to export Dudley’s housing shortfall. Duty to Cooperate: The Duty to Cooperate has not been fulfilled and the unmet housing need identified has been deferred rather than dealt with, contrary to NPPF paragraph 35(c).
5 Sustainability Appraisal: The Draft Sustainability Appraisal fails to consider all of the options available to meet the LHN as well as the GBBCHMA’s unmet need, and therefore would not be justified as per NPPF paragraph 35(b).
6 The Deliverability of Brownfield Land: The proposed supply of brownfield land and windfall sites is an unrealistic and unviable strategy. In reality, the shortfall of housing land is greater than what has been stated within the DLP.
7 Transitional Arrangements of the Draft NPPF: Based on the current arrangements, it is considered unlikely that the DLP will proceed through examination.
8 Exceptional Circumstances and Green Belt Release: The DLP does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for housing. The DLP does not recognise that exceptional circumstances for the release of land from the Green Belt exist.
As a result, St Philips strongly contend that draft Policy DLP1 is unsound as it fails to acknowledge and address the unmet housing need arising from the GBBCHMA, and instead seeks to increase the shortfall and defer this matter to other authorities. An approach that is fundamentally contrary to NPPF paragraphs 35(b & c), as the Duty to Cooperate has not been fulfilled.
Enclosed table demonstrates a shortfall of 38,498 dwellings in the Black Country which is also going to be exported to neighbouring authorities, highlighting the level of pressure the BCA’s are already under.

Duty to Cooperate
This confirms that Dudley is yet to agree to a Statement of Common Ground with the neighbouring HMA authorities in regard to how the contributions will be distributed within the Black Country. There is therefore a degree of uncertainty in regard to how Dudley’s housing shortfall will be met. In the absence of any signed SoCG, there is no agreement between the Councils, raising concern on the certainty associated with the distribution of the allocated and emerging contributions given that there is significant shortfall within the GBBCHMA.
Sustainability Appraisal
As currently presented it appears there is no justification for the three housing options appraised, other than to achieve a predominantly brownfield-led development strategy, resulting in a shortfall which is to be exported to neighbouring authorities. As such, St Philips maintains its stance that the SA, which underpins Draft Policy DLP1, is unjustified as it does not take into account all reasonable alternatives for meeting the unmet housing need and providing a sufficient contribution toward the HMA’s unmet housing need, contrary to paragraph 35(b) of the NPPF.
Deliverability of brownfield land can be challenging, as set out in full in the representation. St Philips consider no one spatial strategy approach should be taken in isolation, and it is considered that a mix of brownfield and greenfield/Green Belt land is necessary to meet the Council’s housing needs and make provision for a mix of types and tenures of dwellings to meet specific needs in line with the requirements of paragraphs 60,63 and 64 of the NPPF.

NPPF Reform
Given the substantial increase in LHN of 143%, the Council is strongly encouraged to pause the progress of the DLP and identify a sufficient land supply to meet the required LHN at the earliest stage of plan production. Due to the significant scale of LHN, it is considered entirely reasonable and consistent with the NPPF for the Council to release Green Belt land to assist in addressing their own housing needs and supporting the GBBCHMA.

Notwithstanding St Philips position that the DLP should be complying with the draft NPPF, should the plan proceed through examination it its current format, the Council still cannot meet its existing LHN, let alone, the proposed LHN from the revised NPPF. As such, under the transitional arrangements of the NPPF in paragraphs 226-229, given the substantial increase the LHN, the Council will be required to undertake a local plan review immediately to identify a housing supply to meet the revised LHN. As a minimum, St Philips considers it appropriate at this stage of plan-making to safeguard land in order to quicken the process as part of the next LP review.

Comment

Representation ID: 1270

Received: 06/12/2024

Respondent: Stratford District Council

The specific wording of proposed policy DLP1, point 3 states that full housing and employment land requirements will be met through identified sites and “through reliance on neighbouring and other local authorities who have a functional link with Dudley via the Duty to Cooperate”. It then goes on to state that “Those development needs that cannot be accommodated within the Dudley administrative area will be exported to sustainable locations in neighbouring local authority areas” As discussed above, neither Stratford or Warwick districts share a boundary with Dudley Borough and therefore are not neighbouring authorities. Whilst acknowledging that Dudley MBC and Stratford DC are both members of the GBBC Housing Market Area, it is noted that there is no specific reference to a functional link or historic migration pattern between Dudley and South Warwickshire in the Publication Local Plan or its accompanying evidence base.

Object

Representation ID: 1281

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 development strategy outlined in Policy DLP1 confirms the intention to deliver at least 10,470 new homes during the plan period to 2041, alongside at least 22.62ha of employment land. The policy goes on to confirm that the full housing and employment land requirements will be met through identified sites, and through reliance on neighbouring and other local authorities. It is considered that this is not an appropriate approach to plan-making by Dudley Council, in the current policy context and whilst other authorities in the local area are facing such significant housing shortfalls as identified above. It is maintained that the Borough should at least be planning to meet its emerging housing needs in full, and potentially also considering whether a meaningful contribution towards other authorities unmet housing needs could be delivered within the Borough as identified above.

Object

Representation ID: 1308

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Summary of Policy DLP1: Development Strategy

The policy is criticized for being unsound, as it lacks justification, effectiveness, and alignment with national policies. Key concerns include:

Failure to meet housing and employment needs within Dudley: The policy proposes that Dudley will rely on neighbouring authorities to meet some of its housing and employment needs through the Duty to Cooperate. However, neighbouring areas are also facing unmet needs, which casts doubt on this approach’s feasibility.

Unmet housing and employment needs: In the Regulation 18 consultation, Dudley planned to meet only 90% of its housing and 35% of its employment needs within the borough, exporting the remainder. The revised version of the plan reduced housing targets further, raising concerns about the adequacy of housing provision and employment space.

Lack of evidence and transparency: The plan does not provide clear evidence of how unmet needs will be addressed by neighbouring authorities. The housing target should be higher, and a Green Belt review is suggested to accommodate additional sites within Dudley.

Duty to Cooperate concerns: Relying heavily on neighbouring authorities to meet housing needs is not seen as reasonable. Dudley must do more to meet its own needs, reducing the reliance on external support.

Housing target should be recalculated: The housing requirement must be properly set before considering land supply. The current approach might not sufficiently address the housing crisis, and the council is urged to reassess its housing target and explore all options, including reviewing the Green Belt.

National Planning Policy Framework (NPPF) alignment: Dudley’s housing requirement should start with the standard method based on household growth projections, but it needs further consideration of other factors, such as economic growth, infrastructure investment, and affordability.

Plan period and Green Belt: The plan’s 15-year period may not be long enough to meet housing needs, particularly if Green Belt release is needed. An extension to the plan period and a Green Belt review are suggested.

Recommendations:

Dudley needs to set a higher housing requirement, addressing both unmet housing and employment needs.
Consideration of Green Belt release is necessary to meet these needs.
The plan should be more transparent, with specific sites identified for development, especially to meet the housing and employment needs within Dudley’s boundaries.
More detailed evidence and consultation should be provided before relying on neighbouring areas to meet Dudley’s needs.
In conclusion, the policy needs to be revised to ensure that Dudley can fully meet its housing and employment needs within its own boundaries, with an emphasis on a Green Belt review and stronger planning for future growth.

Support

Representation ID: 1311

Received: 06/12/2024

Respondent: Lichfield District Council

It is noted that the proposed housing requirement for the Dudley Local Plan is 11,169 homes between 2024 – 2041, as
detailed within Policy DLP1 Development Strategy and Table 5.1. This is based on the current Standard Method used to
calculate the Local Housing Need (LHN) for Dudley. Comments relating to possible future changes to LHN are set out later
within this representation.
Of this total need, it is noted that the Dudley Local Plan aims to deliver 10,470 new homes primarily through a ‘brownfield
first approach’, with 97% of the supply on brownfield land and 3% on greenfield land. This leaves a shortfall of 699 homes
that the plan states cannot be delivered within Dudley and will need to be exported through the Duty to Cooperate. It is
noted in Policies DLP49 and DLP3 that Dudley MBC (DMBC) will not be looking to review its Green Belt boundaries in order to
accommodate this shortfall.
The approach towards calculating Dudley’s own local housing requirement and the site selection process is noted, though
Lichfield District Council is concerned that DMBC’s spatial strategy does not commit to addressing the GBBCHMA shortfall
and may not have thoroughly explored all opportunities to increase housing delivery within its administrative area, including
reviewing its Green Belt to ascertain whether changes could be made to accommodate its own need. As such, LDC considers
that this unmet need could represent exceptional circumstances for reviewing DMBC’s Green Belt boundaries. Furthermore,
DMBC should identify any further potential sources of housing land supply and ensure that all development opportunities
within its administrative area are maximised prior to any shortfall being exported to other areas.

Object

Representation ID: 1345

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Consider the policy will not deliver the necessary housing to meet the need in the area. Does not account for revised standard methodology in the NPPF. Concerned there will be a substantial amount of unmet need to be accounted for by surrounding local authorities.

Comment

Representation ID: 1355

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

CPRE notes that Dudley MBC is planning housing and employment land targets that are less than its objectively assessed needs. This means that the Plan will be unsound unless the council can obtain commitments from other LPAs to meet the deficit between Dudley’s needs and its land supply.

Dudley MBC may have complied with its duty to cooperate, but that does not mean that adjacent LPAs have complied with their duty to cooperate with Dudley.
The undeveloped areas of the adjacent South Stafffordshire to the west and Bromsgrove to the south are substantially all Green Belt, except land allocated for their own respective needs.
Wyre Forest to the southwest (not quite adjoining) allocated slightly more land for housing than it needed in its most recent Plan, but some of the highway connections with Dudley Borough are in some cases only via roads that are highly congested at peak times: A449, A456, A491, A451

Unmet housing need in adjoining areas. Telford and Shropshire might have surplus, but unlikely to provide homes in Dudley.

Object

Representation ID: 1365

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 development strategy outlined in Policy DLP1 confirms the intention to deliver at least 10,470 new homes during the plan period to 2041, alongside at least 22.62ha of employment land. The policy goes on to confirm that the full housing and employment land requirements will be met through identified sites, and through reliance on neighbouring and other local authorities. It is considered that this is not an appropriate approach to plan-making by Dudley Council, in the current policy context and whilst other authorities in the local area are facing such significant housing shortfalls as identified above. It is maintained that the Borough should at least be planning to meet its emerging housing needs in full, and potentially also considering whether a meaningful contribution towards other authorities unmet housing needs could be delivered within the Borough as identified above.

Object

Representation ID: 1415

Received: 29/11/2024

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Should be planning over and above standard method for housing need. The representation sets out why housing need should be higher including need for affordable housing and rising affordability ratio.

There has been a fundamental failing in considering sufficient reasonable alternatives within the Sustainability Appraisal (SA) in relation to a range of housing need and growth options.

Timescales for examination show the representations have not been given due consideration. Any significant changes proposed after Regulation 19 should be published as an addendum and consulted on. This is required with this plan.

Green belt should be removed.

Sustainability Appraisal - to comply with PPG, the growth options should be sufficiently distinct to highlight the different sustainability implications so that meaningful comparisons can be made. It is essential that DMBC take an unbiased and policy-off approach to identifying growth options, which clearly is not how the SA has been approached to date.

See full rep for detailed comments on SA.

Comment

Representation ID: 1426

Received: 29/11/2024

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Section 5

Rep promoting Land at Bromwich Lane.

The above representations have been supported by the submission of a Vision Document; A Pedestrian Access Technical Note (ref. BLSB-BWB-ZZ-XX-RP-TR-0001-TN3); A Transport Technical Note on Access Strategy (ref. PLB-BWB-GEN-XX-RP-TR- 0001-Access Strategy-S3-P02); A Flood Risk Assessment (ref. PBL-BWB-ZZ-XX-RP-YE-0001_FRA); and A Flood Risk Assessment Summary (ref. PBL-BWB-ZZ-XX-RP-YE-0002_FRA Summary Letter_S2-P1). All submitted by email to the Council on 29th November 2024.

Object

Representation ID: 1438

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

Policy DLP1 Development Strategy
The PCCWM objects to the current wording of Policy DLP1 and requires amendments to strengthen the policy, and in particular sub-paragraph 2.a. to read: Delivering high quality development in the existing urban area supported by infrastructure to meet the needs of communities and businesses supported by the integration of Secured by Design principles. [Suggested changes in bold and underlined).

Comment

Representation ID: 1442

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP1 of the emerging DLP establishes that the Council intends to plan for the delivery of at least 10,470 new homes during the plan period to 2041, alongside at least 22.62ha of employment land. The policy goes on to confirm that the full housing and employment land requirements will be met through identified sites, and through reliance on neighbouring and other local authorities. It is considered that the Borough should at least be planning to meet its emerging housing needs in full, and potentially also considering whether a meaningful contribution towards other authorities unmet housing needs could be delivered within the Borough as identified above. This is considered to be necessary in order to ensure that the Local Plan is capable of being found sound at Examination, given that the Duty to Cooperate cannot be retrospectively addressed.
4.2.
The spatial strategy identifies the level of housing expected to be delivered at each of the identified centres, as well as in each of the proposed Regeneration Corridors. This confirms that the majority of the Borough’s housing and employment needs will be delivered within those centres and corridors. Additionally, small and large site windfall allowances are proposed, as well as a windfall allowance from Dudley Council site disposals and an uplift allowance from centres. Together, this confirms how the Council expects to deliver c.10,470 new dwellings (net) and 22.62ha of employment land. This approach is supported in principle, however the Plan should be planning to meet housing needs in full, in order to be consistent with national policy. In particular, where Paragraph 23 of the Framework requires that “strategic policies should provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period, in line with the presumption in favour of sustainable development.” In order to satisfy these requirements and be capable of being found sound at examination, the Council should ensure that sufficient sites are allocated to meet the emerging housing needs in full.

Comment

Representation ID: 1472

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterate suggested approach at Regulation 18 stage, of focussing on main canal specific policy DLP36 rather than repeated mention of the canal/river network within other plan policies. Suitable cross-referencing within justification text however would remain beneficial. Wish to engage with the Council in forthcoming local design codes.