Support

Representation ID: 926

Received: 21/11/2024

Respondent: Dennis R Whittaker

The objectives sound good - but, given the limited success of proposals in previous such Plans, achieving those objectives will not be easy and many of them will fall by the wayside - particularly in these uncertain times.

Object

Representation ID: 1117

Received: 29/11/2024

Respondent: Birmingham and Black Country Wildlife Trust

Legally compliant? No

Sound? No

Duty to co-operate? Yes

We would object to any development over SINCs, SLINCs, PSIs, priority habitats, or sites with priority species. In accordance with the National Policy Framework and Guidance, all public authorities have a duty to conserve and enhance biodiversity and must “have regard” to relevant local nature recovery strategies in the process. Protecting and enhancing the natural environment through sustainable development, integrating green and blue infrastructure, and integrating the priorities and measures of the Local Nature Recovery Strategy will contribute to Dudley Council's legal compliance (see longer comment for specific legislation and policies), and to meet the council's aims and objectives.

Object

Representation ID: 1139

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The approach taken to and reliance on the scale of housing proposed within these described Growth Network is objected to. Whilst these locations could still accommodate some development, it must be part of a more balanced portfolio of deliverable sites. The expected delivery of 2,730 dwellings within the Strategic Centres is not deliverable over the plan period, places too greater emphasis on these locations without clear evidence on deliverability, market evidence on demand or housebuilder interest and clear transparent trajectory on delivery (this noting the appended Trajectory which is absent of any detailed explanation or detailed list of supply sites which contributes to the annual expected delivery).

The same objection is put to the expected delivery of some 2,322 new homes within regeneration corridors. These objections are in the context of the overall concerns about the undue and unrealistic expectations for delivery within the urban area, repeating past failures for delivery in these locations.

Key challenges associated with these sources of supply are numerous, are not resolved within the plan to demonstrate deliverability and include (but are not limited to);
- Multiple land ownerships constraining delivery
- Timeframes, costs and issues associated with land acquisition
- Relocation of existing businesses and uses on site, including business viability to move and the availability of alternative suitable premises
- Land contamination
- Land stability and former historic uses
- Unsuitability of service and key development infrastructure
- Accommodating policy requirements for sustainable drainage and BNG
- Viability generally
- Ability to accommodate other general sustainable building policy requirements viably.

Support

Representation ID: 1159

Received: 29/10/2024

Respondent: St Modwen Homes

Agent: RPS

This policy is supported, however in light of the housing shortfall identified in respect of Policy DLP2, it is considered that the Council should be seeking to increase the amount of housing to be delivered in both the Core Regeneration Corridors and Areas. This in particular should include identifying all opportunities for residential development on the edge of the the urban area, recognising that such locations are typically the most sustainable.

Comment

Representation ID: 1184

Received: 28/11/2024

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

As currently prepared it is considered that the regeneration corridors are not protecting existing
employment land and properly identifying the positive role that existing employers play in the economy
of the Borough. Our client’s land interests at Bott Lane have been excluded from the identified local quality
employment areas. This is inconsistent with the current draft of the Lye and Stour Valley masterplan. The
masterplan acknowledges that the Engine Lane / Bott Lane area currently operates well as an area of
employment and recommends that the existing employment use is retained for the foreseeable future.
The regeneration corridors should be consistent with the more local level studies and plans that have been
prepared.

Object

Representation ID: 1210

Received: 28/11/2024

Respondent: Clowes Development LTD

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Clowes land interests at Ham Lane/Oak Lane sit right on the edge of Regeneration Corridor 1 as identified in the draft DLP – Kingswinford to Pensnett.

As drafted the Regeneration Corridor 1 will not deliver its overall purpose. Table 5.1 identifies that the Corridor is only proposed to deliver 585 dwellings between 2024-2041 and only 3.08ha of land for employment uses. If Regeneration Corridors are to be a focus for growth as set out in draft Policy DLP1 then they should be accommodating as much growth as possible and all options, including Green Belt release, should be considered.

There is land available near the Regeneration Corridors, such as Clowes’ land interests at Ham Lane/Oak Lane that could deliver development to meet Dudley’s identified needs in a suitable and sustainable location.
The Site was considered in the Green Belt Assessment within a Wider parcel of land (Parcel B45) where the overall parcel was considered to contribute to the purposes of including land within the Green Belt as follows:
• Strong contribution to checking the unrestricted sprawl of urban areas
• Strong contribution to safeguarding the countryside from encroachment
• Weak/no contribution to preventing the merging of towns
• Weak/no contribution to preserving the setting and special character of historic
towns

The site itself was not assessed in terms of its contribution to the Green Belt, but it is considered that its contribution to Green Belt is more limited than other areas within the same parcel may be.
The Plan is currently unsound as it is not justified, it has not considered all reasonable alternatives or land available to meet its own needs, in locations that would support its proposed Development Strategy.

Support

Representation ID: 1282

Received: 27/11/2024

Respondent: Dudley Group NHS Foundation Trust

Number of people: 2

Agent: Claremont Planning Consultancy

In regards to Policy DLP2 – Growth Network, the approach identified through this policy maintains consistency from the adopted Development Plan, and continues to direct homes and other developments to the most sustainable locations in the Borough. In particular, the continued identification of the regeneration corridor between Brierley Hill and Stourbridge through RC2, The Draft Plan confirms that this represents a corridor that is extremely well connected to the rest of the region and hosts vibrant local centres. As such, high quality housing is to be focused within centres and along this corridor, with access to green infrastructure. This policy aspiration is welcomed and supported, recognising that within this identified corridor there is a range of services and facilities and good access to public transport, thereby representing highly sustainable location to direct further development towards.

Object

Representation ID: 1315

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The policy on Growth Network Regeneration Corridors and Centres (DLP2) is considered unsound by the Home Builders Federation (HBF) because it lacks justification, effectiveness, and alignment with national policy. The HBF emphasizes the need for the Local Plan to provide a broad range of deliverable and developable sites to ensure housing needs are met, offering competition and choice. It advocates for a logical settlement hierarchy that addresses all housing market areas, including both strategic and non-strategic site allocations, whether brownfield or greenfield. The HBF suggests that additional housing allocations, including potential Green Belt sites, may be needed and that the locational strategy should be reviewed as part of a Green Belt review. The soundness of specific site allocations will be evaluated during the Local Plan Examination.

Support

Representation ID: 1366

Received: 27/11/2024

Respondent: Charles Church Homes

Number of people: 2

Agent: Claremont Planning Consultancy

In regards to Policy DLP2 – Growth Network, the approach identified through this policy maintains consistency from the adopted Development Plan, and continues to direct homes and other developments to the most sustainable locations in the Borough. In particular, the continued identification of the regeneration corridor between Brierley Hill and Stourbridge through RC2, The Draft Plan confirms that this represents a corridor that is extremely well connected to the rest of the region and hosts vibrant local centres. As such, high quality housing is to be focused within centres and along this corridor, with access to green infrastructure. This policy aspiration is welcomed and supported, recognising that within this identified corridor there is a range of services and facilities and good access to public transport, thereby representing highly sustainable location to direct further development towards.

Support

Representation ID: 1443

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

The draft Policy outlines a Growth Network for the Borough, focusing on new development, regeneration, and infrastructure investment to support growth and benefit local communities. Section 3 highlights that Regeneration Corridors will deliver at least 2,322 new homes and 22.6 hectares of employment land in sustainable locations.

The proposed Growth Network approach is supported, as it directs development to the most sustainable areas, aligning with the Black Country Core Strategy and the Dudley Borough Development Plan. The vision for Regeneration Corridor 3 (Stourbridge to Lye), promoting high-quality residential communities with parks, employment, and transport links, is particularly endorsed.

The allocation of land off Thorns Road (DLP H017) for residential development is strongly supported, given its sustainable location. This site is close to public open spaces, employment areas, and local services, all easily accessible by sustainable transport, contributing positively to the vision for Regeneration Corridor 3.