Comment

Representation ID: 1475

Received: 29/11/2024

Respondent: Canal and River Trust

Reiterates previous Regulation 18 comments.

Content that canal-specific implications arising from the draft Housing need and supply policies and allocated sites can be adequately addressed through the issues-specific polices identified elsewhere in this response, and in particular the use of Policy DLP36. The inclusion of the canal network within relevant allocation maps helpfully enables developers to identify canal related constraints at an early stage and engage with us. Requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice directly.

The Trust can provide information of priority areas for upgrading on a case-by-case through responses to planning application consultations, and will seek to request Section 106/CIL monies and/or planning conditions if appropriate. The Trust has some specific critical assets within the Dudley area especially within Brierley Hill and along the Dudley No 1 Canal, as well as over Trust tunnels, which will require careful assessment of allocations for impact and mitigation under Policy DLP36 – Canals.

Object

Representation ID: 1514

Received: 29/11/2024

Respondent: Feoffess of Oldswinford Hospital (Foundation)

Agent: Turley

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Draft Policy DLP10 of the Dudley Local Plan aims to deliver at least 10,470 new homes by 2041. However, the Foundation argues that this target is unlikely to be met due to several issues:

1. **Reliance on Occupied Employment Sites**: A significant portion (11%) of the proposed housing supply comes from occupied employment sites (1,204 homes). There is no evidence to show these sites are available or deliverable, and some have been allocated since 2017 without progress. These sites should be removed from the housing supply.

2. **Viability Issues with Brownfield Sites**: Most of the priority sites for development are brownfield sites, with four out of five deemed "marginal" in terms of viability. These sites require significant investment for remediation, infrastructure, and overcoming constraints. The Council's Viability Assessment suggests that external funding (such as grants) will be needed to unlock many of these sites, but such funding is not guaranteed. Relying on sites that depend on uncertain funding could undermine the delivery of housing.

3. **Brierley Hill Strategic Centre**: The plan expects 1,546 homes to be delivered in Brierley Hill, but so far only 564 homes have been built, against an indicative target of 2,939 homes. Housing delivery is expected to increase with the completion of the Metro Extension, but this has been delayed due to funding issues. Until these issues are resolved and evidence is provided, the Brierley Hill site should be removed from the plan.

4. **Regeneration Corridor 2**: The proposed 972 new homes for this area are questionable due to a significant shortfall in delivery (only 1,171 homes have been built against a target of 2,060). Given past delivery rates, it is unclear whether the target can be met within the plan period, raising concerns about the feasibility of the housing strategy for this corridor.

In conclusion, the Foundation argues that there is insufficient evidence to demonstrate the deliverability of the proposed housing supply in the plan, and the issues outlined could prevent the target of 10,470 homes from being met.

Comment

Representation ID: 1545

Received: 29/11/2024

Respondent: Historic England

Policy DLP10 Clause 3

Could reference the need to consider mitigation/enhancement measures from the Heritage Impact Assessment for housing allocation sites.

Comment

Representation ID: 1546

Received: 29/11/2024

Respondent: Historic England

Housing Section on Page 128

There is no reference under evidence base to the Heritage Impact Assessment that has been prepared to inform the site allocations.

Object

Representation ID: 1611

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL has concerns about the Council's housing land supply outlined in Table 8.1 of the Plan. Despite a 699 dwelling shortfall, the sources of housing land supply are uncertain. For sites with planning permission, it is unclear if an implementation allowance has been applied, which typically would be around 10%. The Plan relies on redeveloping existing employment sites, but past efforts to do so under the Black Country Core Strategy were not successful. WL questions the reliability of this source and suggests a higher non-implementation allowance should be applied.

Additionally, the Plan includes a windfall allowance of 184 dwellings per year, which WL finds too high (nearly 25% of the total requirement) and lacking compelling evidence of reliability. Other sources, like occupied employment sites and office redevelopments in Brierley Hill, face uncertainties about when they will contribute to housing supply. The Plan’s overall housing supply is pegged at 10,470 homes, exactly matching the proposed requirement, but WL argues this leaves no buffer if certain sites don’t come forward as expected.

WL objects to Policy DLP10, believing it is ineffective and unlikely to meet the housing requirement due to uncertainties around land supply and delivery. A higher level of over-allocation is needed to address potential shortfalls.