Support

Representation ID: 927

Received: 21/11/2024

Respondent: Dennis R Whittaker

Objectives sound good - but success depends on action not words - and action depends on will and money.

Comment

Representation ID: 1018

Received: 27/11/2024

Respondent: Glen Dimplex Group

Agent: Glen Dimplex Group

Policy DLP3 - Areas Outside the Growth Network Policy DLP3 refers to areas outside of the identified Growth Network setting out a vision for what these areas will include. It states that the main role of areas outside of the Growth Network are to provide employment opportunities to serve communities outside the Regeneration Corridors and Centres and to provide a supply of housing land at appropriate densities. The broad approach to development in areas outside the Growth Network will be to primarily focus on brownfield land, in locations with best access to local services and infrastructure. Glen Dimplex support the inclusion of such a policy which provides guidance for those sites outside of the identified Growth Network, which could play an important role in delivering the housing and employment requirements of the Borough, particularly in response to changing markets. However, this draft policy suggests that weight is attached to such sites outside of the Growth Network, yet only allocates 343no. dwellings in such locations (set out in policy DLP1).

We respond specifically on the housing allocation for the Glen Dimplex site later on in this response, and are indeed supportive of such an inclusion. However, with regard to the soundness of this particular general policy we query whether it would be more effective if proportionate housing growth was attributed to these areas, particularly where there is strong connections with facilities, services, and also neighbouring authorities.

Object

Representation ID: 1033

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Sandwell considers the policy to be unsound. Although Dudley have looked to utilise previously developed sites within the urban area and by increasing densities, the plan should review the Green Belt, especially as there are sites, previously identified as suitable, that would enable the council to meet its need in full.

Comment

Representation ID: 1076

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Part 5 of the policy confirms that the Council’s Green Belt boundaries will be maintained and protected from inappropriate development. In light of the comments, we have set out in respect of policy DLP 1 above Barberry object to this approach on the basis that maintaining the Green Belt and seeking to direct growth to only previously developed sites will result in housing need being unmet and a shortage of employment land being delivered through the Plan unless the Council is able to agree with other authorities in the HMA for them to accommodate some of this unmet need. As noted previously the Council had intended to release land from the Green Belt when preparing the Black Country Plan in order to not only meet Dudley’s needs but contribute to meeting the wider needs of the HMA. Barberry reiterate that the release of land from the Green Belt within Dudley will help ensure that Dudley is able to meet its housing requirement of 11,169 in full within its own administrative areas without having to resort to its adjoining neighbours. The decision to not release land from the Green Belt to meet Dudley’s needs in full will have a number of adverse consequences for the supply of new homes and particularly the delivery of affordable homes, making the aspiration for home ownership beyond the reach of many who live in the Borough.

Barberry object to the Plan and consider it unsound on the basis that it is not positively prepared nor will be it be effective and that by not reviewing the Green Belt to meet the Council’s housing needs in full within its own administrative areas will result in a number of problems association with lack of adequate housing, housing affordability and knock on economic impacts arising from a lack of working age people able to live and work in the Borough.

Object

Representation ID: 1164

Received: 27/11/2024

Respondent: Mrs Eleanor Lovett

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Whilst this Plan benefits from the proposed transitional arrangements set out in the draft NPPF
(which is likely to become the actual NPPF by the end of 2024) the Government encouragement of
review and release of Green Belt should be considered by the Council. As this Plan currently fails to
plan for sufficient housing to address local housing needs in full, it is clear that the previous Plan-led
approaches of focusing on sites within built up areas and regeneration corridors will not be
sufficient going forward. As such, the Council should be considering other opportunities to meet
housing needs on a strategic scale, which may require the review and release of Green Belt.

Comment

Representation ID: 1213

Received: 05/12/2024

Respondent: Walsall Council

Dudley’s Green Belt boundaries will be maintained and protected from inappropriate
development”. The word ‘boundaries’ should be omitted: it is areas within the Green Belt
that should be protected, not the boundaries.
Accessibility Standards
The means of transport to which these relate should be stated. Are they walking, cycling,
car or bus journey times?

Object

Representation ID: 1317

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP3, which addresses areas outside the Growth Network, is considered unsound by the Home Builders Federation (HBF) due to a lack of justification, effectiveness, and alignment with national policy. HBF stresses the importance of providing a wide range of deliverable sites to meet housing needs.

The policy's statement that Dudley’s Green Belt will be protected from inappropriate development is challenged by HBF, which argues that the current housing crisis and Dudley’s inability to meet its housing needs justify a Green Belt review. This review should consider both employment and housing sites. HBF also references national policy (NPPF para 11 and para 60), emphasizing the need for sustainable development that meets housing requirements and boosts housing supply to avoid delays.

HBF supports ambitious growth in Dudley and highlights the link between employment growth and housing demand. They argue that failing to provide enough housing will negatively impact economic and social well-being. Given Dudley’s inability to meet its housing needs, HBF believes Green Belt release is necessary to ensure a sufficient Housing Land Supply (HLS) and meet housing delivery targets, including the 5-Year Housing Land Supply (5YHLS) and Housing Delivery Test (HDT).

Additionally, HBF suggests that the Council should consider whether biodiversity net gain (BNG) development could be acceptable within the Green Belt and whether Green Belt boundaries should be revised to accommodate such developments.

Comment

Representation ID: 1347

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Welcome clarification that housing will be allocated on land outside of the Regeneration Corridors and Centres (this version of the plan contrasts with the original plan that proposed using "surplus land"). Unfortunate that allocations in the DLP are so reliant on redeveloping brownfield land. The viability of these projects is questioned, as the high proportion of brownfield land may struggle to deliver the necessary community benefits and affordable housing due to challenges with land values, build costs, and sales values in Dudley.

Object

Representation ID: 1513

Received: 29/11/2024

Respondent: Feoffess of Oldswinford Hospital (Foundation)

Agent: Turley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Following on from Policy DLP1, draft Policy DLP3 is also not considered to be sound given it intends to maintain the borough’s Green Belt boundaries without any review. As per our response to Policy DLP1, NPPF Paragraph 109 states that new development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This paragraph does not limit new development to brownfield sites only.

Object

Representation ID: 1610

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Part 5 of the policy confirms that the Council’s Green Belt boundaries will be maintained and protected from inappropriate
development. In light of the comments we have set out in respect of policy DLP1 above WL object to this approach on the
basis that maintaining the Green Belt and seeking to direct growth to only previously developed sites will result in housing
need being unmet and a shortage of employment land being delivered through the Plan unless the Council is able to agree
with other authorities in the HMA for them to accommodate some of this unmet need. To date we cannot see that any
agreement of memorandum of understanding has been signed that demonstrates where these needs are to be met. WL
reiterate that the release of land from the Green Belt within Dudley will help ensure that Dudley is able to meet its housing
requirement of 11,169 in full within its own administrative areas without having to resort to its adjoining neighbours. The
decision to not release land from the Green Belt to meet Dudley’s needs in full will have a number of adverse consequences
for the supply of new homes and particularly the delivery of affordable homes, making the aspiration for home ownership
beyond the reach of many who live in the Borough.
WL object to Policy DLP3 and consider it unsound on the basis that it is not positively prepared nor will be it be effective and
that by not reviewing the Green Belt to meet the Council’s housing needs in full within its own administrative areas will result
in a number of problems associated with lack of adequate housing, housing affordability and knock on economic impacts
arising from a lack of working age people able to live and work in the Borough.