Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 297

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

WDH does not object in principle to the delivery of brownfield sites, but highlights in response to Policy DLP10 that the identified sites are unlikely to deliver the level of growth suggested in the policy. Therefore WDH are of the view that DMBC must identify additional allocation sites, including those located in the Green Belt, without delay.

Comment

Representation ID: 298

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

Can be very complex and protracted involving landowner issues, relocating existing tenants, contamination of land. Build out rate is slower on brownfield sites compared to greenfield, as per Lichfields report.

There are a number of factors that are likely to reduce the capacity of each allocation site, if and when they come forward including site constraints, space for POS and BNG. It is imperative that DMBC take full consideration of the factors influencing the deliverability of each individual site.

Object

Representation ID: 299

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

Housing Allocations.

The policies do not provide a concept plan or alike that would suggest where built development may be located or how the suggested capacities could be achieved. Rather, allocation capacity figures appear to be derived from the Strategic Housing Land Availability Assessment (SHLAA), which itself merely applies crude blanket assumptions based on the site area and an assumed density.

Object

Representation ID: 300

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

Table 8.1 Windfall Allowance

To satisfy the NPPF tests in relation to exporting unmet housing needs, it follows that the DLP must have identified all brownfield development sites that are available at this point in time. Therefore, whilst some new brownfield sites may become available, it is difficult to see how there would be additional capacity at this scale when the identification of such a number of brownfield sites both within the DLP and extant plans will inevitably have depleted the supply of available brownfield sites. Until such evidence has been prepared, it is suggested that a 50% reduction to the current windfall allowance should be applied, reducing the annual allowance to 90dpa. By excluding the first two years (as per the DLP), but applying the figure over the extended plan period between 2023 and 2043, that would result in a windfall supply of 1,620 dwellings; which is still a substantial quantum of delivery from such sites.
When applying the proposed deduction to the windfall allowance to reflect a more realistic level of delivery, it is likely that the DLP will actually deliver at most 6,898 dwellings (but likely fewer) against the residual housing requirement of 10,223 dwellings. That will result in a shortfall of at least 3,325 homes (but likely significantly higher once the housing requirement is uplifted).

Comment

Representation ID: 302

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

Table 6.1 Housing Allocations - Site Assessment

Should also assess the overall suitability of promoted Green Belt sites, rather than simply refusing to assess them because they are located within the Green Belt.

Object

Representation ID: 307

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd on behalf of William Davis Homes

Sustainability Appraisal

Moreover, the insufficient and delayed delivery of housing that is currently proposed will only perpetuate the existing housing crisis and further heighten the effect of the associated socio-economic consequences on Dudley’s residents. This should be reflected in Sustainability Appraisal (SA) testing of various levels of growth, which (as set out below) the DLP currently overlooks entirely. In assessing the environmental impacts of failing to meet the Council’s housing need, the SA must also reflect that failing to meet Dudley’s housing needs in full will also result in less sustainable patterns of growth.
The SHMA must identify a range of higher level growth options, at which point an updated SA must also be prepared to test the potential effects relating to each of the growth options. The SA should recognise the socio-economic and environmental impacts of failing to meet the Borough’s housing needs as set out above. However, the current SA falls a long way short of meeting that requirement. In relation to the quantum of residential development, the SA assesses an extremely narrow range of options that each are built on the assumption that DMBC will be unable to meet their own housing needs and that an urban-focused strategy is the only potential option. That approach suggests that the spatial strategy pursued through the DLP was pre-determined (likely based on political considerations), and that the evidence base has simply evolved to seek to justify the agreed approach. he SA should, therefore, test the impacts of meeting the LHN in its entirety and providing for higher level(s) of growth above the LHN, through a ‘policy off’ approach (i.e. setting aside policy constraints such The outcome of that will assist in identifying an appropriate housing requirement that provides for an aspirational strategy for Dudley.
The SA has not tested the release of any Green Belt land in any scenario (with an implicit acceptance that DMBC will not be able to meet its housing need), nor has the SHLAA assessed any Green Belt sites. That must be addressed in light of the significant unmet needs arising in the Dudley.