Object

Representation ID: 908

Received: 10/11/2024

Respondent: Ms Susan Pearson

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We don’t have infrastructure to support more houses . Health services struggle caring for residents currently. Ambulances regularly queue at the hospital with patients waiting to be seen , more residents means further increases . There’s constant shortages of hospital beds , more residents increasing need. Roads are constantly too busy, extra vehicles would cause gridlock.
Schools are over subscribed. residents cannot afford increases in council tax to support the demand for more services.
Dudley is full ! We need to preserve green spaces. It is irresponsible to take on more residents when we struggle caring for current ones

Support

Representation ID: 934

Received: 21/11/2024

Respondent: Dennis R Whittaker

No further comments.

Object

Representation ID: 1036

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that Dudley have looked to utilise previously developed sites within the urban area and increasing densities, but this plan hasn’t reviewed the Green Belt even though there are sites, previously identified as suitable, that would enable the council to meet its housing need in full.

Object

Representation ID: 1063

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 DLP10 on the basis that it is not effective, and as it is, the sources of supply that have been identified would not be sufficient to meet the housing requirement as proposed and that due to various reasons relating to non-implementation or delivery of certain sites/sources of supply there would be a shortfall in supply against the housing requirement. In order to address Bloor’s concerns additional land should be made available to protect against any non-implementation that may occur and to allow flexibility in meeting the needs.

Object

Representation ID: 1078

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Putting the shortfall aside we have a number of concerns about the sources of housing land supply that the Council sets out in Table 8.1 of the Plan.

In respect of sites with planning permission or prior approval it is not clear whether a non-implementation allowance has been applied to this source of supply. Typically, a 10% non-implementation allowance would be applied to such sites.

Table 7 of the SHLAA also identifies potential supply from occupied employment sites albeit that a 15% non-implementation allowance has been applied to this source. It is noted that reliance on redevelopment of existing employment sites was a key theme for delivering new houses through the adopted Black Country Core Strategy. However, the intended strategy was not wholly successful as issues relating to the release of multi-ownership employment sites did not result in significant new residential development coming forward. Furthermore, retention of employment sites in employment use proved commercially as viable, if not more viable, than developing for residential use. The outcome being that a number of employment sites that had been earmarked for residential development remained, and continue to remain, in employment use. It is questionable whether the same reliance on existing employment sites to deliver new residential development in the current Plan would have resulted in a different outcome. As such, the application of only a 15% non-implementation allowance seems on the low side and that a much higher non-implementation allowance should be applied. Due to the uncertainties associated with this source of supply coming forward and making any meaningful contribution to the supply of housing there is an argument to say it should be removed completely from the potential supply of new homes.

A windfall allowance of 184 dwellings per year has also been allowed for. Whilst the Framework confirms that where an allowance is made for windfall sites as part of the anticipated supply there should be compelling evidence that they will provide a reliable source of supply. The windfall allowance that has been allowed for equates to nearly 25% of the total housing requirement which is a significant proportion of the overall supply that is expected to come forward on non-allocated sites. It is also noted that the windfall allowance is on top of the supply that is also identified on occupied employment land sites and other sites within town centres and the regeneration corridors.

In respect of occupied employment land sites such as those identified in Brierley Hill there is again a question mark over whether these will come forward and specifically when they will come forward for development. Whilst Table 8.1 indicates that these would not start contributing to the supply until 2028 there is no certainty that this source of supply will contribute to the overall supply of housing.

Table 8.1 also includes a centre uplift allowance which accounts for a number of sites increasing the density of development that that site is capable of accommodating. Whilst in theory this may be possible there is a question mark over whether this would actually deliver as intended. Due to the uncertainty that this will occur and the limited contribution it makes to the overall supply this element of the supply should also be removed.

A further source of supply is from a redevelopment of offices in Brierley Hill waterfront. This has been included on the basis that office demand has decreased following the Covid pandemic and that the office capacity would be available for redevelopment for housing through the plan period. More recently, there has been a slew of announcements from companies publicly stating that they want their employees to return to the office. There is a degree of uncertainty over whether existing offices will be available for redevelopment in the volumes that are envisaged and as such it cannot be guaranteed that the element of supply would be deliverable. If it did take place this would be considered a windfall and doesn’t need to be identified as a separate source of housing in the supply.

Totalling up all the sources of supply in Table 8.1 equals 10,470 homes. This is the same number as the proposed housing requirement set out in the Plan. The Plan does not propose to over-allocate against the housing requirement in case for whatever reason certain sources of the supply do not come forward as expected. As it stands, all sources of the supply would have to come forward to meet the housing requirement (albeit there is still a shortfall of 699 homes against what is actually needed). This risks the housing requirement not being met in full if sites do not come forward as anticipated and we have set out above there are a number of risks with certain elements of the supply that may not deliver as intended.

Clearly, if the Council were to over-allocate against the housing requirement this would identify additional sites for housing that could meet the Standard Method housing requirement that the Council are currently stating that they cannot meet in full. As it stands Barberry are concerned that the sources of supply that have been identified would not be sufficient to meet the housing requirement as proposed and that due to various reasons relating to non-implementation or delivery of certain sites/sources of supply there would be a shortfall in supply against the housing requirement. In order to address this, additional land should +be made available to protect against any non-implementation that may occur.

Barberry object to policy DLP10 on the basis that it is not effective and not consistent with National policy and if adopted in this form will result in significant additional housing need going unmet beyond the 699 homes that the Council are currently not planning for.

Object

Representation ID: 1141

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We have fundamental concerns regarding the quantum of need identified, its distribution, and how it will be met. These concerns are set out here principally in relation to the housing requirement, but should be understood in the context of the strategic points made separately.

The concerns raised here in reference to Policy DLP10 are far reaching and point to a fundamental failing of the draft DLP to meet the tests of soundness set out in the Framework. They consider both the quantum and distribution of housing proposed in the draft DLP in principle and then the proposed components of the draft DLP’s anticipated supply in more detail.

Quantum and Distribution of Unmet Housing Need in Dudley over the emerging Local Plan period
Draft DLP sets out that this will accommodate only 94% of current Local Housing Need up to 2041. In other words, the draft DLP acknowledges, at the outset, that it will fail to deliver almost the minimum number of homes needed in Dudley over the Plan period. This is even acknowledging that LHN is a starting point minimum need, with it also important to understand how increases to this need may, for example, bolster affordable housing provision to better fully meet need, or support overall delivery or contribute to other economic objectives of the plan. We would fully expect the Local Plan to identify well in excess of the minimum need in order to allow for a choice in range and type of sites and allow for potential under delivery. Most Local Plans include a buffer provision of at least 10% provision. Not only is this plan not providing a buffer, but it is not even meeting the minimum need. A buffer of at least 10% would be the minimum additional buffer needed in Dudley given the significant concerns in respect of allocation deliverability set out elsewhere in these representations. DLP10 should in this context plan for additional allocations to meet the minimum need.

These levels of affordable housing will not be met given challenges to viable delivery of housing, such that a greater number and range of sites well above LHN is needed in order to address affordable housing needs. Further, this fails to grapple with un-met need from neighbouring Authorities which is known and where Dudley may well offer opportunities to actually accommodate a greater level of growth, assisting in meeting the needs of neighbours rather than seeking to export its own needs elsewhere. This is set out elsewhere in our representations but questions the housing requirement of the plan where there is no evidence of any certainty on wider unmet needs. 97% brownfield is not a balanced approach.

Dudley is asking its neighbouring authorities to deliver most of its employment land requirement. How does Dudley plan to deliver its acknowledged unmet housing need (700 homes) over the draft DLP period, if it cannot demonstrate its neighbouring authorities will assist through DTC; and the second is that the draft DLP relies very heavily on brownfield sites, including currently occupied employment sites and sites previously used for employment purposes, to deliver its deficient housing requirement, which flies in the face of its identified (very) significant shortfall of employment land, which Dudley is looking at its neighbours to help deliver.

As such, many of Dudley’s neighbouring authorities which it might need to rely on to deliver its acknowledged shortfall of housing say they are also unable to deliver their own requirement.

Distribution of the draft DLP’s Anticipated Housing Supply
Delving deeper into the draft DLP’s key component sources of housing land supply, the very serious concerns raised above from the headline unmet need figure are exacerbated. In addition to the above, the components of housing land supply within Policy DLP10 are not sound and similar to Table 5.1 need to be fundamentally revisited. The sources of supply need to be critically reviewed. There is significant potential for the sites not to deliver the scale of housing anticipated within the timeframes required. Many are subject to significant constraints.

Table 8.1 sets out an indicative phasing for which there is no justification. The requirement should not be phased in a national housing crisis and there is no evidence to explain why a phasing of delivery would be appropriate or acceptable. In any event, the phasing should be replaced by a trajectory, for which objections have been raised elsewhere about the limited value of that provided in Appendix 4.


Detailed concerns highlighting shortcomings in the components of the draft DLP’s anticipated supply as offered by DLP10 are set out as follows (numbered i – iv): [see full rep for detail]
i. Deliverability of Longstanding Brownfield Sites - historic underdelivery
ii. Windfall - overreliance
iii. Demolitions in Dudley Borough - Dudley’s 10 year housing asset management strategy (2019) identified around 2,500 homes (some 12% of the Council’s stock) that are considered not viable and are red-flagged for review for strategic investment, de-investment or demolition. In doing so it acknowledges that this may result in an overall loss in housing capacity but is subject to detailed consultation.

Object

Representation ID: 1158

Received: 20/11/2024

Respondent: Wood Abbey

Agent: NCL Development

Legally compliant? No

Sound? No

Duty to co-operate? No

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: 1161

Received: 29/10/2024

Respondent: St Modwen Homes

Agent: RPS

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Quantum and Distribution of Unmet Housing Need in Dudley over the emerging Local Plan period
Plan does not meet minimum LHN - no evidence / justification that shortfall will be met through DtC.

Reliance on brownfield sites which can be challenging to deliver.

Shortfalls within wider HMA and FEMA.

Ultimately, the draft DLP fails to address in any tangible way how the minimum number of homes needed in Dudley over the DLP period can ever be delivered. As a result, it fails to meet any of the tests of soundness set out at Paragraph 35 of the Framework. Unless remedied the emerging Plan risks being found unsound and failing to be adopted.

Greenbelt release is necessary.

Moreover, the draft DLP includes a 15% discount of housing supply from allocated sites on occupied employment land in recognition of the ‘multiple delivery constraints’ typically affecting such sites – raising questions as to whether these sites in the anticipated housing supply are truly viable, suitable or developable for residential use.

BCCS placed great emphasis on brownfield land and failed to deliver.

Heavy reliance on windfall sites.

Object

Representation ID: 1165

Received: 27/11/2024

Respondent: Mrs Eleanor Lovett

Legally compliant? Yes

Sound? No

Duty to co-operate? No

This policy is proposing to deliver 10,470 new dwellings, despite this being less than the identified
local housing needs for the plan period. This should be rectified, with sufficient housing allocations
to meet the need in full, identified.
A secondary concern relates to the sites proposed to be allocated. It is apparent that the Council is
proposing to allocate sites that have either already been, or are in the process of being, delivered.
This is clearly not what plan-making is for, and the Council should consider whether the proposed
allocation are available and/or deliverable.
Overall, it is considered that before the Plan progresses any further, the approach to housing
allocations should be reviewed. Where sites have already been delivered, these should not be
proposed to be allocations, and instead further sites should be allocated to contribute towards
meeting the Borough's housing needs, in full.

Object

Representation ID: 1205

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

. Goldfinch Town Planning Services continues to have concerns that the council’s planning policy team continues to take forward undeliverable housing site allocations within its emerging Local Plan Review, in direct conflict with deliverability-focused guidance set out under paragraphs 16 (indent b) and 35 (indent c) of the Revised NPPF (December 2023). The tests of soundness for Local Plan preparation are set out within paragraph 35 of the Revised NPPF (December 2023). Paragraph 35 (indent c) of the Revised NPPF (2023) is perfectly clear in its view that: “…Local plans and spatial development strategies are examined to assess whether they have been prepared in accordance with legal and procedural requirements, and whether they are sound. Plans are ‘sound’ if they are: (indent c) Effective – deliverable over the plan period…”

18. The significant imbalance in the spatial distribution of new housing development across the Dudley Metropolitan Borough being brought forward through the council’s emerging Local Plan Review (2024/ 2025) needs to be urgently addressed by Dudley Council’s Planning Policy Team, within a significantly more heavily revised, more fit-for-purpose and environmentally sustainable planning policy approach. Heavily urbanised parts of the Halesowen, Stourbridge, Brierley Hill and central Dudley urban areas in particular are being completely over-loaded within increasingly unsustainable levels and environmentally damaging patterns of new development. Heavily urbanised parts of the Dudley Metropolitan Borough are already at maximum capacity levels and cannot accommodate any further new development growth within the inner urban area. Some Green Belt release should therefore be considered by the council’s planning policy team within lower quality parts of the Green Belt, to reflect the significant recent planning policy shift in central government (London) planning guidance. Within its current plan-making approach, the Regulation 19 consultation report (October 2024) is currently failing the “Sustainability” tests of soundness as specified under paragraph 35 (indent d) of the Revised NPPF (December 2023). Given the emerging Local Plan Reviews ongoing refusal and continued failure to promote the most environmentally sustainable patterns of new housing development.

The significant spatial imbalance in the distribution of new development across the Dudley Metropolitan Borough being taken forwards through the Local Plan Review is highly concerning. The environmental quality of the urban area is being severely damaged as part of a seemingly increasingly more desperate urban cramming planning policy approach.

. To help clarify the position for Dudley Council, put quite simply, there is a clear limit to how much new development a specific part of the urban area can continue to accommodate. We have concerns that the Council and its town planners, surveyors, transport engineers and urban regeneration specialists are all still failing to grasp these critically important and basic issues. The Halesowen, Stourbridge, Brierley Hill and central Dudley urban areas continue to be over-loaded with increasingly unsustainable patterns of new development, which is damaging to the local environmental quality, and damaging to the health and well-being of hundreds of thousands of local residents who live within heavily urbanised and densely-populated parts of the Dudley Metropolitan Borough. The emerging Local Plan Review is failing to promote the most sustainable patterns of new housing development in direct conflict with the “Sustainability” tests of Soundness as specified under paragraph 35 (indent d) of the Revised NPPF (December 2023).

. The proposed Plan-making approach is failing to respond effectively to wildlife corridor focused guidance set out under paragraph 185 of the Revised NPPF (December 2023) which reinforces that: “…To protect and enhance biodiversity…, plans should (indent a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological network, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping-stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and (indent b) promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity…”
22. The council’s planning policy team is promoting irresponsible patterns of new development and damaging the environmental quality of the Dudley Borough inner urban area, just to appease local politicians in respect of Green Belt matters. Heavily urbanised parts of the Dudley Metropolitan Borough continue to suffer from a failed, naive and ineffective planning policy protection approach.
23. The position is perfectly clear, Dudley Council is not promoting the most environmentally sustainable patterns of new development within borough within its emerging Local Plan Review, and the approach being taken by the Council on these matters is therefore in direct conflict with a range of sustainable development focused guidance as reinforced within paragraphs 7, 8, 10, 11, 16 (indent a), 35 (indent d), 38, and 157 – 159 and 185 of the Revised NPPF (December 2023).

The Council’s Planning Policy Team is not promoting climate change resilience measures within its proposed spatial planning policy approach being taken towards the distribution of new development within the emerging Local Plan Review (2024/ 2025). We are alarmed that the council’s planning policy team considers it appropriate to re-develop established urban woodlands within heavily constrained urban areas for new housing development – within the inner urban area, and develop other important urban green space areas within the inner urban area for new housing, just to save some low quality Green Belt locations. The plan making approach being taken forward by the LPA strongly conflicts with climate change resilience focused national planning guidance set out under paragraphs 157 to 159 of the Revised NPPF (December 2023). The
emerging Local Plan Review is failing the “Sustainability” tests of Soundness
as specified under paragraph 35 (indent d) of the Revised NPPF (December
2023).

No transparent transport assessments have been generated to support the various proposed new housing site allocations being brought forward across the urban area through the council’s emerging Local Plan Review (2024). The transport evidence is obscure and far too vague, and therefore provides insufficiently robust evidence. This is particularly relevant given the completely unsafe, tightly constrained and dangerous character (from a highway safety perspective) of many of the urban sites being brought forward for new housing development through the Local Plan Review. The position is clear, the proposed Plan-making approach being taken forward by the LPA within its emerging Local Plan Review is not based on proportionate evidence and therefore fails soundness tests specified under paragraph 35 (indent b) of the Revised NPPF (December 2023).

The proposed urban cramming of 10,471 new homes (over the shelf-life of the new Local Plan period extending up to the year 2041) solely within the inner urban area will result in the loss of extensive areas of sensitive urban green space areas which currently provide a critically important outdoor recreational resource, serving heavily populated urban areas. These urban green space areas located on the doorstep of local communities play a critically important role in helping to promote more physically active healthy lifestyles. The proposed urban cramming approach being taken towards housing delivery within Dudley Council’s emerging Local Plan Review (2024/ 2025) will make the out-of-control obesity crisis which continues to disproportionately affect the Dudley Metropolitan Borough and neighbouring Walsall far worse. The proposed Plan-making approach being taken forwards by Dudley Council’s Planning Policy Team is therefore making the out-of-control local obesity crisis even far worse and failing to promote the most environmentally sustainable patterns of new development - in direct conflict with the ‘Sustainability’ tests of soundness as set out under paragraph 35 (indent d) of the Revised NPPF (December 2023). The plan-making approach being taken forwards by Dudley Council’s planning policy team is also conflicting with a range of health-focused guidance set out within paragraphs 8 (indent b), 96 (indent c) and 102 of the
Revised NPPF (December 2023). The council is damaging the local area

The scale of excessive and completely disproportionate new residential development growth being proposed solely within the Dudley Borough inner urban area is promoting inappropriate, damaging and unsustainable patterns of development within the local area. Based on 4 cars per household, the proposed 10,470 number new build residential dwellings being proposed over the lifespan of the new Local Plan (extending up to the year 2041) will generate an additional 41,880 vehicle trips on the already heavily constrained, heavily pressured and heavily congested highway networks within the Dudley Borough inner urban area. Which already suffers from severe levels of traffic congestion. The inner urban area various housing site allocations will result in enormous adverse residential amenity impacts affecting established local communities living within heavily urbanised parts of the borough. As well as result in



enormous adverse impacts on the heavily constrained highway networks which are unable to accommodate and cope with this significant scale of new traffic growth. The proposals being taken forwards and forced-through within the Regulation 19 Local Plan consultation report are just completely unsustainable. Within the Local Plan Review, the council should be exploring the release of Green Belt land south of Stourbridge for major new housing development in order to help relieve pressures within the inner urban area. The current plan- making approach is failing the “Sustainability” tests of Soundness set out under paragraph 35 (indent d) of the Revised NPPF (December 2023). The Council’s Planning Policy Teams continued refusal to consider reasonable alternatives to the growth strategy (e.g. considering Green Belt release south of Stourbridge) is also failing Soundness tests set out under paragraph 35 (indent b – failure to consider reasonable alternatives) of the Revised NPPF (December 2023).

Comment

Representation ID: 1240

Received: 05/12/2024

Respondent: Walsall Council

Concerns that the plan proposed a reduction in the supply of land for housing compared with that proposed in the BCP. The surplus of 1151 homes relatives to need over the plan period proposed in the BCP was to reduce to a shortfall of 1076 homes. This was as a result of the intention not to allocate land that is currently in Green Belt. The BCP proposals for Dudley included the provision of housing slightly in excess of local need to contribute towards the needs of Sandwell, and to a lesser extent Wolverhampton. The draft DLP however proposed to supply less than enough to meet local needs, which means that this shortfall will need to be exported to neighbouring authorities.

Comment

Representation ID: 1242

Received: 05/12/2024

Respondent: Walsall Council

The publication version of the plan proposed a similar shortfall in the land to be supplied. The stated housing shortfall reduced from 1076 to 699 but this is because the plan period has reduced by a year. Dudley consider the Shortfalll is allowed under the December 2023 NPPF which states there is no requirement for Green Belt boundaries to be reviewed.

Comment

Representation ID: 1244

Received: 05/12/2024

Respondent: Bromsgrove District Council

The attempt at meeting the housing and employment needs of Dudley is acknowledged. As is the shortfall of 699 dwellings, and 50 Hectares of employment land. It is unfortunate that Dudley has decided not to meet its needs in full. We question whether the conclusion that there are no exceptional circumstances to release Green Belt sites is sound, particularly as a previous version of the Black Country Plan was directing growth to Green Belt sites in Dudley. The potential contributions from other authorities, would appear to offer some form of solution to meeting the needs in full, but clearly a position needs to be reached on how these contributions are to be distributed for this plan, and other plans in the HMA to be found sound. It is known that a Statement of Common Ground is being prepared to address apportioning this growth and it will be for the Examination in Public to determine the soundness of this approach.

Comment

Representation ID: 1255

Received: 06/12/2024

Respondent: South Staffordshire Council

The draft plan identifies a supply of 10,470 dwellings against a calculated requirement of 11,169 homes leaving a marginal unmet need of 699 dwellings. SSC will continue to work closely with Dudley Metropolitan Borough Council (DMBC) alongside the other relevant partners consider unmet needs across the housing market area through the relevant working groups and duty to cooperate arrangements.
SSC has recently completed a consultation on an updated Publication Plan (Regulation 19). It should be noted that SSCs preferred strategy in its April 2024 Regulation 19 consultation is to meet the housing needs of our communities by focusing growth primarily on the district’s most sustainable Tier 1 settlements, including some Green Belt release at these settlements on sites assessed as suitable through our site assessment process. This does result in a potential 640 home surplus based on our current standard method requirement that could be attributed to unmet needs of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA).
We would support a commitment to continued attempts at increasing the supply of dwellings identified within the borough. Specifically, attention should focus on examining the scope for increased densities particularly in the larger urban centres, reallocation of sites from other uses were this doesn’t conflict with other plan objectives, housing area renewal proposals and exploring the potential release of Green Belt sites including those sites identified in the now abandoned draft Black
Country Plan. Such contributions will reduce the overspill requirement arising within Dudley and potentially make a contribution towards addressing housing market shortfalls in the wider Greater Birmingham and Black Country Housing Market Area.

Comment

Representation ID: 1266

Received: 06/12/2024

Respondent: Stratford District Council

Dudley’s Local Housing Need stands at 11,169 homes using the current Standard Method. The Local Plan’s proposal to deliver at least 10,470 new homes (94% of their Local Housing Need) leaves a shortfall of 699 homes. In line with national policy, there is a requirement for any housing or employment unmet need to be provided for across the relevant Housing Market Area, Functional Economic Market Area (FEMA) or other areas with which Dudley has a strong physical or functional relationship. A number of local authorities have made offers of housing and employment land contributions to assist in addressing the wider GBBCHMA shortfall or specifically the shortfall of the Black Country Authorities (who were previously working together on a joint Black Country Plan), however it is acknowledged that these contributions need to be formally confirmed as part of the Local Plan process and examination of each authority’s Local Plan. The Duty to Cooperate Statement at para 4.11 also states that the four Black Country Authorities have been working on an approach to determine how the contributions from outside the HMA could be apportioned between those authorities with a shortfall of housing supply., with the suggested approach being to use migration data and the functional relationship between the exporting area and the authority where the shortfall exists.

Comment

Representation ID: 1269

Received: 06/12/2024

Respondent: Stratford District Council

The South Warwickshire Local Plan is at an early stage of preparation and as such it is not yet known whether the needs of South Warwickshire can be met within the two districts, particularly in light of the potential significant increase in Local Housing Need arising from the proposed changes to the Standard Method, as proposed in the draft NPPF (July 2024). Therefore, at this stage, Stratford cannot make a commitment to assisting Dudley with meeting any of its unmet need. Whilst we are committed to continuing to work with our partner authorities across the GBBCHMA on an update to the 2018 Growth Study and an evidenced method to apportion any unmet need across the authorities, it would be premature to put forward any contributions that have not been derived from this joint work. However, we would take the opportunity to highlight as we have in our previous responses to you, that in the event that there may be a request/need for South Warwickshire to
accommodate any unmet housing need, then this would need to be considered in light of any necessary supporting infrastructure requirements and how this would be funded. SDC has a particular concern regarding how any infrastructure costs that cannot be directly attributed to a specific development will be met, noting previous infrastructure deficiencies from development in the district. In relation to a site which is meeting unmet need from another authority, there should be an arrangement between the exporting and receiving authorities to address any funding shortfall.

Comment

Representation ID: 1272

Received: 06/12/2024

Respondent: Stratford District Council

Regarding Dudley’s Green Belt, we would reiterate the comments we made at the Regulation 18 stage of the Local Plan. Given that the identified housing shortfall (and employment shortfall) could have been accommodated within Dudley’s 1,770ha2 of Green Belt through fairly moderate release of land, it is disappointing to see that this option has not been explored further in the Publication Local Plan. There is very limited commentary within the Local Plan itself explaining the rationale behind this decision. It is noted that the supporting evidence base document ‘Spatial Strategy Development’ (October 2024) touches on this matter, stating at para 4.16 that “Dudley’s housing and employment shortfalls are not considered significant”, and that therefore it is “considered that exceptional circumstances [to justify a review of Green Belt boundaries] have not been triggered”. The West Midlands Green Belt is extensive and all members of the GBBCHMA have land designated as Green Belt within their authority areas. Therefore, by protecting Dudley’s Green Belt, but suggesting that Dudley’s unmet needs are exported to surrounding authorities, Green Belt in other local authority areas could become under pressure for release. As the July 2024 draft NPPF proposed extensive changes to national policy regarding Green Belt and the triggers for a review of boundaries, the anticipated revised version of the NPPF may require that Dudley’s proposed approach is revisited

Comment

Representation ID: 1277

Received: 06/12/2024

Respondent: Birmingham City Council

Since the Preferred Options consultation for the DLP was done in 2023, the housing and employment land requirement figures have been updated and amended. Policy DLP1 sets out that the Strategy will deliver 10,470 net new homes and 22.6 hectares of employment land. Table 5.1 states that the housing need for Dudley, using the Government’s existing Standard Methodology, specifies that land for 11,169 homes is required by 2040/41. As with the Preferred Options document, the Policy sets out the context of how the development choices for Dudley have been made, primarily seeking to deliver development within the Borough’s Centres and Regeneration Corridors. These choices mean that land for only 10,470 homes can be identified, leaving a shortfall and unmet housing need of 699 homes (a reduction of 379 since the Preferred Options document was published).As mentioned in our response to the DLP Preferred Options, it is therefore important that Dudley continues to strive to accommodate as much housing and employment as possible to meet its own needs by making effective use of land and maximising densities and much of the DLP achieves this which is supported by the City Council. However, as previously expressed, this should also include opportunities to carry out development on the edge of the conurbation, including the release of land from the green belt as has been done in other local authorities over the last few years including Birmingham, to promote sustainable patterns of growth in line with paragraph 147 of the NPPF. This has made a significant contribution to the housing and employment land shortfalls within Birmingham through the Langley Sustainable Urban Extension and the Peddimore employment site. The latter allocation has helped in potentially enabling Birmingham to fully meet its employment land needs in the new Local Plan period up to 2042. As previously mentioned, other Councils within the Birmingham and Black Country HMA have also released Green Belt land in order to contribute to meeting their own housing and employment needs as well as contributing to the shortfall of the HMA.In view of the issues highlighted above, Birmingham City Council previously expressed disappointment that sustainable housing development sites on land currently in the Green Belt in Dudley and elsewhere in the Black Country had been removed from the potential housing supply having previously been included in the preparation and consultation of the Black Country Plan. This would have provided much needed housing growth, supported by Green Belt review evidence, to alleviate the issues highlighted above as part of sustainable patterns of growth on the edge of the conurbation in the same way that green belt land has been released in other parts of the HMA, including Birmingham.

Comment

Representation ID: 1279

Received: 06/12/2024

Respondent: Birmingham City Council

The City Council appreciates the development pressures that Dudley, along with all local authorities across the West Midlands, is experiencing in terms of mounting housing and employment land requirements. This is further exacerbated by recent and proposed changes to the NPPF which has also had the effect of delaying or disrupting local plans and their timetables. In the DLP, Dudley has taken steps to maximise its brownfield development potential which is supported by the City Council. However, in view of the mounting shortfalls of housing land provision across the GBBCHMA, many authorities, including Birmingham, have made difficult decisions to maximise development opportunities further such as removing land from the Green Belt as a last resort when all other options have been exhausted. The City Council has previously expressed its disappointment that, having
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previously had the opportunity to alleviate some of those shortfalls by removing some sites from the green belt, Dudley have now chosen not to replicate the approach taken elsewhere and have taken these sites out of consideration. The consequence is that housing and employment opportunities will either be exported to other parts of the HMA further away from where the housing need is derived or lost altogether.
This is particularly important given the potential changes to the NPPF and the housing needs methodology which are likely place a higher burden on Dudley in meeting its future housing needs and helping to meet the housing and employment land needs across the GBBCHMA and the West Midland Functional Economic Market Area under the Duty to Cooperate. The high levels of potential unmet housing and employment land needs being experienced across the conurbation are likely to continue under any proposed housing needs methodology. This could also be considered as an exceptional circumstance to justify taking sites out of the Green Belt, as done elsewhere, in line with paragraphs 145 and 146 of the current NPPF. Reconsideration of the additional site allocations originally proposed in the BCP Preferred Options would be in line with the approach taken by other local authorities in the West Midlands in adopted or proposed local plans and would assist in removing any doubts surrounding the soundness of the DLP in being positively prepared and in accordance with the Duty to Cooperate. In addition, proposed changes to the NPPF and housing needs methodology by the new Government will necessitate careful consideration by Dudley to ensure that, firstly, transitional arrangements are being fulfilled and secondly, if so, an early review of the DLP is made to ensure that the requirements of the proposed new NPPF and housing needs methodology are fully explored and appropriately planned for by Dudley going forwards.

Object

Representation ID: 1285

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? Yes

The draft Plan proposes to deliver at least 10,470 new homes by 2041, but it is argued that this figure does not fully address the Borough’s housing needs, and the plan period itself is considered inadequate. To meet the soundness tests of the Framework, it is suggested that the plan period should be extended to 2043, and additional housing allocations should be made to ensure full housing need is met. The Council's approach to housing allocations is criticized, particularly regarding the inclusion of sites already constructed or under development, which should not count towards future allocations. It is further noted that sites with planning permission or previously allocated but undeveloped sites need robust evidence of suitability and availability to be relied upon in the Plan. Constraints on delivering housing from brownfield sites and former employment land are acknowledged, with discounts applied to their delivery projections, but these sites still face significant delivery challenges. The Council is advised to revisit both the housing supply and the sites it is relying on to ensure the Plan meets national policy requirements. Additionally, sites like Land at Corbett Hospital, located in a highly sustainable urban area, could be included as a housing allocation to address housing shortfalls. This revision would enhance the Plan's ability to meet emerging housing needs and meet the delivery requirements.

Support

Representation ID: 1298

Received: 06/12/2024

Respondent: Worcestershire County Council

We support that the housing and employment land needs can be met without requiring development opportunities in the Worcestershire County Council local authority area. We would, however, recommend that a ‘Monitor and Manage’ approach would be appropriate to provide sufficient surety that development would not have unacceptable cross-boundary highway capacity and safety impacts.

Object

Representation ID: 1320

Received: 28/11/2024

Respondent: Home Builders Federation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP10 on Delivering Sustainable Housing Growth is considered unsound by the Home Builders Federation (HBF) due to lack of justification, effectiveness, and alignment with national policy.

Housing Requirement: HBF advocates that the housing requirement for Dudley should start with the Standard Method for Local Housing Need (LHN) as a minimum, and then consider factors like site variety, flexibility, and viability to potentially increase the requirement. They argue that insufficient sites are allocated, and further allocations, including greenfield and Green Belt sites, are necessary.

Housing Number and Phasing: HBF requests a clear explanation of how the housing requirement number is determined and that the policy should include an annual housing target for effective monitoring. They also believe the housing requirement should be higher, with higher numbers allocated in each phase of the plan.

Viability and Flexibility: HBF supports including discounts for non-implementation rates but argues that the current approach lacks flexibility and doesn't offer enough choice. They stress that flexibility should come from additional allocations (including windfalls) rather than relying on discounted sites that are unlikely to be delivered.

Brownfield vs. Greenfield Land: HBF is concerned about the unrealistic reliance on brownfield land for 97% of new housing. While supporting a "brownfield first" approach, they emphasize that greenfield sites are crucial to meeting the housing crisis, offering a range of sites for different types, tenures, and needs. This may include Green Belt land if necessary.

Small and Medium Developers: HBF calls for more small sites (less than 1 hectare) to be allocated to support small and medium-sized (SME) housebuilders, who have historically contributed a significant portion of housing supply. They suggest that a higher percentage of small sites should be allocated to encourage SME growth and faster build-out rates.

Windfall Sites: HBF expresses concern about the over-reliance on windfall sites for housing supply, arguing that they should only be counted from the fourth year of the housing trajectory. They also believe windfall sites should not replace allocated sites, as they do not offer the same flexibility or choice.

Monitoring and Housing Trajectory: HBF stresses the need for a detailed, site-by-site housing trajectory within the Local Plan for effective monitoring. The trajectory should include clear projections, break down housing sources, and address regeneration plans.

Greenfield Development: HBF reiterates the need for greenfield allocations, including potentially Green Belt land, to meet Dudley’s housing requirement. They suggest that if housing delivery underperforms, additional greenfield sites may need to be brought forward.

Object

Representation ID: 1346

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: 1354

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

There appears to be a further town centre housing opportunity site, between DLP.SH3 and Coventry Street. Some of this is needed for rear access to shops and for car parking (which is important in Stourbridge), but it should be possible to build above ground floor level. This site would include the Royal Mail yard, Eagle House Car park, and land near the end of Coventry Street that is currently used as a small municipal car park. This would provide an active frontage to St Johns Road (ring road). This is in multiple ownerships, so that Dudley MBC might have to use compulsory powers to facilitate land assembly. We suspect there may be further sites in and around Stourbridge and other town centres that could be allocated

Object

Representation ID: 1371

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? Yes

The draft Plan proposes to deliver at least 10,470 new homes by 2041, but it is argued that this figure does not fully address the Borough’s housing needs, and the plan period itself is considered inadequate. To meet the soundness tests of the Framework, it is suggested that the plan period should be extended to 2043, and additional housing allocations should be made to ensure full housing need is met. The Council's approach to housing allocations is criticized, particularly regarding the inclusion of sites already constructed or under development, which should not count towards future allocations. It is further noted that sites with planning permission or previously allocated but undeveloped sites need robust evidence of suitability and availability to be relied upon in the Plan. Constraints on delivering housing from brownfield sites and former employment land are acknowledged, with discounts applied to their delivery projections, but these sites still face significant delivery challenges. The Council is advised to revisit both the housing supply and the sites it is relying on to ensure the Plan meets national policy requirements. Additionally, sites like Land at Corbett Hospital, located in a highly sustainable urban area, could be included as a housing allocation to address housing shortfalls. This revision would enhance the Plan's ability to meet emerging housing needs and meet the delivery requirements.

Object

Representation ID: 1385

Received: 09/12/2024

Respondent: Clowes Development LTD

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

The emerging Dudley Local Plan (Regulation 19 version) states that 699 dwellings are required to be exported through the Duty to Cooperate. Point 3 of policy DLP1 states that:
“…Those development needs that cannot be accommodated within the Dudley administrative area will be exported to sustainable locations in neighbouring local authority areas.”
There is however, no confirmed agreement with other LPAs regarding the provision of this shortfall being exported to other LPA areas. Moreover, the Duty to Cooperate statement within the Regulation 19 version of the emerging Plan is dated October 2023, indicated it has not been updated since the version published with the Regulation 18 version of the Dudley Local Plan in Winter 2023. Thus ongoing engagement is not evidenced, as required by paragraph 26 of the NPPF.

Object

Representation ID: 1389

Received: 09/12/2024

Respondent: Clowes Development LTD

Agent: Savills

Legally compliant? No

Sound? No

Duty to co-operate? No

There is no evidence in support of the draft Plan on whether engagement to date has been constructive and active in an attempt to resolve the strategic matter of unmet housing need and maximise the effectiveness of plan preparation.
Therefore, the plan should not be submitted until further evidence is produced in this regard, and a further Regulation 18 consultation is undertaken to ensure that any shortfalls in the availability of duty to cooperate information can be suitably dealt with before a further Regulation 19 consultation then takes place.
This will ensure that the Council has been able to suitably take into account the comments and queries of stakeholders before the plan is submitted.

Object

Representation ID: 1416

Received: 29/11/2024

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Supported by rep for section 5.

Viability addendum demonstrates the fundamental flaw in DMBC’s approach to not only spatial strategy but also site selection which has an overreliance on brownfield sites which may not be viable or deliverable.

DMBC must allocate further greenfield sites to ensure a sufficient supply and mix of sites and make the Plan sound. Due to the tightly bound nature of the Borough, this will inevitably require a review of the Green Belt.

PLP Table 8.1 suggests that current supply and housing allocations provide around 71% of the gross new homes proposed in the PLP. The remaining 29% would be expected to be provided through windfall development (not including the 699 homes proposed to be exported to other authorities). This is based on an annual windfall rate of 184 homes a year in addition to 564 new homes expected from other sources. Whilst it is acknowledged that windfall rates generally are based on previous delivery, it is anticipated that this would drop significantly under the PLP due to the allocation of significant brownfield sites being allocated for development already. It is expected that DMBC will have made best effort to identify all the available brownfield development sites available before choosing to export its unmet need.

NPPF paragraph 72 states that “Where an allowance is to be made for windfall sites as part of anticipated supply there should be compelling evidence that they will provide a reliable source of supply." The evidence base and PLP fails against paragraph 72. It does not sufficiently demonstrate that the windfall figure, or the specific sites for windfall development are a reliable source of supply. Until evidence of this is available, a significant reduction of 50% should be applied to the windfall allowance.

Appendix 4 housing trajectory contained within the Strategic Housing Land Availability Assessment 2023/24 provides some additional detail however clearly shows that a significant proportion of the identified sites will not deliver until later in the plan period, if at all. It also lacks justification for several sites to demonstrate they can be delivered in the timescales provided, if at all.

Over reliance on brownfield sites - not only can take a lot longer to deliver (if they come forward at all) but also often come forward with reduced public benefit such as affordable housing provision.

As such, there is no evidence that unmet need can be exported to other authorities and exceptional circumstances exist whereby DMBC should undertake a review of Green Belt sites to allocate sufficient quantity and mix of sites within the area to meet the housing need.

Comment

Representation ID: 1444

Received: 29/11/2024

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Policy DLP10 of the draft Plan aims to provide sufficient land for at least 10,470 new homes by 2041 to address the housing figures set out in Table 5.1 and Policy DLP1. However, concerns are raised that this target does not fully meet the Borough’s housing needs for the plan period, and the plan period itself may be insufficient.

Despite these concerns, the allocation of land at Thorns Road (DLP H017) for residential development is strongly supported. This site was previously allocated under the adopted Development Plan (H13.17) and is already partly being developed through a planning application (P22/1363), with delivery expected soon. The remaining part of the site, currently used for employment, will be phased for residential development in the medium to long term.

Object

Representation ID: 1458

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

Strengthening of paragraph 8.2 at Regulation 18 stage through the following addition, ‘New housing will be of a well-designed high build quality, meeting national space and water efficiency standards, achieving high levels of energy efficiency and adapting to climate change and integrating ‘Secured by Design’ and ‘Park Mark principles.’ (in line with the DLP design policies). [Suggested changes in bold and underlined).