Object

Representation ID: 1511

Received: 29/11/2024

Respondent: Feoffess of Oldswinford Hospital (Foundation)

Agent: Turley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The Foundation argues that Policy DLP1 in the Dudley Local Plan is unsound for several key reasons:

1. **Inadequate Housing Provision**: Policy DLP1 proposes the delivery of 10,470 homes, but Dudley’s actual housing need is 11,169 homes. This shortfall contradicts Strategic Priority 6, which aims to meet the full housing needs of the Borough, and does not align with National Planning Policy Framework (NPPF) requirements, where the housing need should be a minimum starting point.

2. **Flawed Alternatives Assessment**: The Sustainability Appraisal (SA) for Policy DLP1 only considers three housing growth options, none of which assess the potential of releasing land from the Green Belt to meet housing needs. The approach to development alternatives is seen as flawed, particularly as greenfield sites are faster to develop than brownfield sites, which are more costly and time-consuming.

3. **Unresolved Shortfall**: The shortfall of 699 homes will be transferred to other local authorities in the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) through the Duty to Cooperate (DtC) process. However, many of these authorities, including Birmingham, Sandwell, and Wolverhampton, are facing their own significant housing shortfalls, and no formal agreements (Statements of Common Ground) have been made to confirm contributions from neighbouring authorities. This uncertainty makes it unlikely that the shortfall can be met.

4. **Lack of Green Belt Review**: The Foundation argues that exceptional circumstances exist to review Dudley’s Green Belt boundaries to meet the housing need. Green Belt land should be considered for residential development, including sites like Racecourse Lane and Worcester Lane in Stourbridge, to ensure a sufficient and diverse range of land is available for housing.

In conclusion, the Foundation believes the proposed strategy in Policy DLP1 is not positively prepared, justified, or deliverable, and calls for a review of the Green Belt to meet Dudley’s housing needs.

Comment

Representation ID: 1598

Received: 29/11/2024

Respondent: National Highways

Note the housing and employment requirements have changed since the Regulation 18 consultation.

Note housing shortfall and welcome Council's initiative to address this through the Duty to Cooperate- would welcome update to understand how the impacts from unmet housing need will be captured.

Table 5.1 indicates a total of 5,395 dwellings as allocations whilst the Part Two Housing allocation details reflects a total of 4,569 dwellings. Welcome clarity on the allocations and recommend an update in the Local Plan for consistency.

Note the employment land shortfall and the removal of allocations since Regulation 18.

Object

Representation ID: 1609

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy DLP1 sets out the Council’s targets for delivering new homes (10,470) and employment land (at least 22.6 hectares) in the Borough. However, WL has significant concerns about how the Council plans to meet its housing and employment land needs, especially considering a housing shortfall of 699 dwellings. While the local housing need is calculated at 11,169 homes, the Council’s plan does not adequately address the shortfall, particularly in the context of potential Green Belt land release. WL argues that Dudley should prioritize using its own Green Belt land before seeking help from neighboring authorities, especially since other local councils (Birmingham, Sandwell, and Wolverhampton) are also facing significant housing shortfalls.

WL contends that the Council’s refusal to release Green Belt land, despite the shortfall, is short-sighted and contrary to the National Planning Policy Framework (NPPF), which allows for Green Belt reviews in exceptional circumstances. WL suggests that factors such as worsening affordability, homelessness, overcrowding, and increased economic pressures justify a review of the Green Belt. They also point out that Worcester Lane was previously identified as suitable for housing development in the Black Country Plan and should be included in the Borough Plan to help reduce the housing shortfall.

Furthermore, the plan does not address how the housing shortfalls in neighboring areas (Sandwell, Birmingham, and Wolverhampton) will be managed, totaling a combined 73,166 homes. WL believes Policy DLP1 is unsound because it fails to meet housing needs, exacerbating issues like affordability and overcrowding, and does not adequately address cross-boundary cooperation between local authorities as required by the NPPF.

Object

Representation ID: 1622

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 Development Strategy takes sufficient steps to meet the Housing Requirement as set and does not make any allowances to assist neighbouring authorities who we know cannot meet their own needs (Wolverhampton, Sandwell and Birmingham). Furthermore, we do not consider that it is properly informed / supported by the Duty to Cooperate, the onus on which has increased notably follow the demise of the Black Country Core Strategy.

Proposed Changes to National Policy

Before we set out the reasons for this, we also note that the Housing Requirement is based on the current Standard Method figure. This is likely to change at the end of the year and the current evidence would suggest Dudley’s Standard Method figure will increase significantly with it. Whether Dudley MBC can avoid this remains to be seen, but if the Council is not successful, the Development Strategy and Duty Cooperate will need to be revisited to meet the requirements of the amended NPPF and the new Standard Method figure