Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 520

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

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.

Comment

Representation ID: 521

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Wording could be clearer and more effective for future residential development proposals.

Part 2 of this policy, states that the range of house types and sizes should be 'in line with the most recently available information" and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"Developments of ten homes or more should provide a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as:
• The Black Country HMA 2021 (or any subsequent revision);
• or Detailed Local Housing Market Assessments (where applicable); or Current and future demographic profiles;
• or Locality and ability of the site to accommodate a mix of housing;
• or Market signals and local housing market trends."

Additionally, paragraph 8.14 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs set out in the HMA", This is not however referred to in the policy wording itself nor does the HMA provide evidence that Dudley MBC will be undertaking a further HMA assessment specific to the authority area. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text needs to be clear about which evidence is to be used to inform housing mix. Paragraph 8.14 and Table 8.3 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.

Comment

Representation ID: 523

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Part 2 is ambiguous whether all of the criterion are required to be met to demonstrate that the loss of an employment use is acceptable, or whether one of them needs to be satisfied. This should be amended for the next version of the Plan to ensure that this is clear. We do not consider that all of the criterion should be required to be satisfied, but rather one or more. This is because to satisfy all of the criterion may potentially lead to conflicting positions, resulting in an overly restrictive policy. We therefore suggest the following additional wording is included to provide clarity:
"Development for uses under 1(b) or 1(c) will only be acceptable where there is robust evidence to demonstrate to the satisfaction of the council that one or more of the following criteria have been met: [...]"

Comment

Representation ID: 524

Received: 21/12/2023

Respondent: Glen Dimplex Group

Agent: CBRE Limited

Policy DLP22 - The wording of Draft Policy DLP22 appears to be similar to Policy DLP21. In particular, point 2 (a) and (b) of Policy DLP 21 and point 2 (a) of Policy DLP22 both discuss the requirement of industrial / employment uses and their viability. Additionally, point 2 (d) of DLP21 and point 2(b) of DLP22 has regard to avoiding adverse impacts upon. It is not clear what the need for two similar policies is, and it is our suggestion that draft policies DLP21 and DLP22 are reconsidered as a single policy, to ensure that there is no duplication which when applied could be confusing and onerous.