Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 301

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Harris Lamb Planning Consultancy is instructed by Barberry Summerhill Limited (“Barberry”) to submit representations to the Draft Dudley Local Plan (Regulation 18 consultation document) and welcome the opportunity to comment at this time.
Barberry are promoting land for residential development at Swindon Road, Wall Heath, Kingswinford (referred locally as the Triangle site) and have previously submitted details of the site to the preparation of the Black Country Plan and previously representations to the Black Country Plan Preferred Options consultation that concluded in October 2021.
The land at Swindon Road, Wall Heath, Kingswinford (“the Site”) had been proposed as a strategic housing allocation in the Preferred Options Black Country Plan under Policy DSA2. The Site was proposed to be removed from the Green Belt and allocated to accommodate approximately 533 homes. Barberry clearly supported the Black Country authorities’ intention to allocate the Site for housing and submitted representations in support of the Site’s suitability to accommodate residential development. However, following the abandonment of the Black Country Plan the Site is no longer identified as a draft allocation and has been omitted from the Plan in its entirety.
The omission of the Site from the Plan is a result of a wider change in strategy that the Council is now advancing, which seeks to focus new development on previously developed land within the urban area. As part of the preparation of the new Local Plan the Council is no longer proposing to release land from the Green Belt to meet its development needs and, further to this, the Council are no longer considering the release of their Green Belt land as an option to meet its housing need, favouring exporting the problem to other yet undefined locations in the Housing Market Area (“HMA”). The recent publication of the updated National Planning Policy Framework (‘The Framework’) states there is no requirement to review of change Green Belt boundaries when plans are being prepared, but it continues to allow authorities to choose to subject to demonstrating exceptional circumstances. In some ways, this is not a significant change from the previous version of the Framework, as there was no requirement to change Green Belt boundaries and exceptional circumstances needed to be demonstrated if Council were proposing to do so. However, it does place more of an onus on Council’s to instigate this process and the weight of responsibility that comes with this should not be underestimated. Where it is identified that Green Belt needs to be released to meet the development needs identified, on the one hand it requires an understanding of the potential environmental impacts that could come from changing Green Belt boundaries, on the other the social and economic disadvantages of meeting the housing and / or economic needs identified. These being real impacts on local people and local business, who will suffer if the needs are not met. In this instance, we consider not delivering the housing need identified will have substantial social and economic impacts for thousands of people and we ask the Council to very carefully consider the impact on these people when deciding whether or not to amend their Green Belt boundary, especially when there are sites that make a limited contribution to the Green Belt could be released to meet this need.
Barberry, therefore, object to the proposed strategy on the basis that the Council has not explored all the options available to meet the housing need and that it has land available in its administrative boundary to meet its housing need identified, including sites that it has previously supported as draft residential allocations in the Black Country Core Strategy review. We consider there are exceptional circumstances that warrant the Green Belt being reviewed and land released from it to help meet housing needs, which include the substantial social and economic impacts for thousands of local people and businesses.
The updated Framework still sets out at paragraph 60 the objective of significantly boosting the supply of housing with the overall aim to meet as much of an area’s identified housing need as possible, including with an appropriate mix of housing types for the local community. Paragraph 61 of the Framework states that to determine the minimum number of houses needed, strategic policies should be informed by a local housing needs assessment conducted using the standard method. Whilst it is clarified that the standard method is a starting point the Framework also states that there may be exceptional circumstances from diverging away from the standard method. The Council has not presented any exceptional circumstances as to why it should diverge from the standard method for calculating housing need, nor do we consider that there are exceptional circumstances as to why Dudley should not use the standard method to determine its housing need. Indeed, it is debatable whether the strategy advanced by the Council will meet the identified need arising in Dudley in terms of delivering sites that are capable of being developed to mee the need that exists, noting that the majority of new homes required are 3 and 4 bedroom properties and not 1 or 2 bedroom apartments.
Paragraph 60 goes on to conclude that in addition to any local housing need figure, any needs that cannot be met within neighbouring authorities should also be taken into account in establishing the amount of housing to be planned for. There is significant pressure across the HMA from constrained authorities who cannot meet their development needs within their administrative boundaries, with tens of thousands of homes and hundreds of hectares of employment land needing to be found. The number of authorities able to assist with this overspill in the HMA are limited and the evidence suggests they cannot be relied upon when the numbers they have proposed in their emerging plans to assist with addressing the overspill do not even scratch the surface. Consequently, where authorities have the land available, we consider they should be using this unless there is an overwhelming persuasive reason as to why that land should not be developed, with the argument that ‘it is Green Belt land’ notstanding up to scrutiny, when it is inevitable that most of the overspill would need to be on land currently designated as Green Belt if the development needs identified are going to be met.
Further to the above, we consider that not only should Dudley be meeting its own housing need, but that it should also be assisting with meeting the overspill from other authorities, such as Birmingham, Sandwell and Wolverhampton, with whom it has a strong functional relationship and that it can provide the land in the locations to help meet the overspill from these authorities close to where the need is arising. We acknowledge that these residents might not fall in your administrative boundary, but when so many people stand to suffer from the lack of land to meet the development needs identified we would implore the Council to not allow administrative lines to stand in the way of helping these people. Accordingly, Barberry have strong reservations about whether the Council’s intended strategy. The tests of soundness remain in the updated Framework as set out in paragraph 35. As it stands, Barberry consider that the Plan is not positively prepared in that does not meet the area’s objectively assessed needs and is not informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development
Below, we start by explaining why we consider Barberry’s Site should still be identified as a residential allocation in the plan, address the concerns raised in the representations to the Black Country Core Strategy Review. We then provide our comments on the draft policies.
Proposed Housing Allocations – Land at Swindon Road, Wall Heath (The Triangle Site)
Barberry are objecting to the draft Plan on the basis that the land at Swindon Road, Wall Heath (the Triangle site) has been omitted as a draft housing allocation, when it has previously been supported by the Council as a draft housing allocation in the Black Country Core Strategy Review and in the context of the significant pressure for authorities within the HMA to meet their own development needs and assist those who cannot wherever possible.
The inclusion of the Site as a draft allocation confirmed that in principle the Site was capable of being allocated for development and delivering new housing development to meet the needs of Dudley. Whilst the Black Country Plan has now been withdrawn the previous assessment work of the site and the conclusions drawn that led it to be included as a draft allocation cannot be discounted and indicate that the site is suitable for development.
We have reviewed the consultation responses to the Preferred Options Black Country Plan and note the level of objections received to this and the other sites proposed to be released from the Green Belt. A list of the general points made in response to the draft allocation are set out in the Summary of Consultation Responses report published by the Council alongside the draft Local Plan consultation. These can be summarised as:
•Lack of existing infrastructure and amenities to cope with additional dwellings.
•Concerns over the existing road network and increased traffic.
•Loss of Green Belt.
•No exceptional circumstances to release Green Belt land.
•Detrimental impact on ecology and biodiversity.
•Loss of Grade 2 and Grade 3 agricultural land.

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Development would result in increased pollution in terms of air, noise and light particularly during construction.
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No economic benefit to the area and impact on house prices.
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Cumulative impact of other developments in the area.
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Brownfield first approach should be taken.
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General concerns regarding flood risk, global warming, heritage and landscape impacts.
Whilst the summary comments are not all specifically directed at the Triangle site a number of the comments that were made were attributable to the draft allocation.
We note the volume of representations, but we also note that both Barberry’s expert project team (see the Vision Document and Delivery Document (attached) prepared to set out our initial assessment and to respond to the draft criteria in the allocation policy during the preferred option consultation respectively) and the Council’s expert consultees have reviewed the technical and environmental matters relevant to this Site, and concluded that the site was deliverable in this context, with measures proposed through the site allocation and the wide policies in the plan that would ensure this was the case when a planning application was submitted.
The loss of Green Belt is the other factor raised in the objections. As highlighted above, the release of Green Belt is not unique to this Site. The land outside the urban area in Dudley is all Green Belt and the same is true for the authorities surrounding Dudley with potential capacity to meet its development needs. Discussions with these authorities will not lead to the concerns around the loss of Green Belt land being resolved. It will just change the location of where Green Belt is being released. The reality is that the only way to address the objection that Green Belt land should not be released is to not meet the development needs identified for Dudley or the wide HMA, and not provide the homes and jobs needed for local people.
Turning to the comments received and general areas of objection raised Barberry respond as follows:
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Existing infrastructure - an assessment of existing capacity in local GPs, schools, use services and sewage and water facilities would have been undertaken as part of the development. If this highlighted that there was a lack of capacity or that the proposed development would place additional demands on existing provision then the developer would be required to mitigate the impact of the development through physical provision of new infrastructure or payment of developer contributions. The impact of the development could be mitigated through such an approach and thus the concerns regarding adverse impact on infrastructure are unfounded. Existing shortfalls in service provision in the local area are not as a result of the proposed development and it would only be the addition demand that any development would need to mitigate.
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Impact on highway and increase in traffic - the proposed development would have resulted in an increase in traffic on the local highway network although the additional impact that this would likely to cause was not considered to be severe. Whilst there may have been localised impacts at specific junctions surrounding the site it is considered that through a scheme of off-site highway improvement works that the impact of this could have been mitigated to an acceptable level. Assessment of accidents in the local area did not indicate that there was a specific highway safety issue that would be exacerbated by the proposed development. Similarly, additional development could have resulted in the provision of
enhanced or additional public transport services brought about by an increase in demand from the new population. This would benefit existing residents as well as new residents of the development.
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The site is located in the Green Belt albeit that it is bound by development to the north and south by built development and is bounded to the west by the A449 creating a strong defensible boundary. The role that the site plays in Green Belt terms is limited and it is contended that its removal from the Green Belt would have limited impact on the overall function of the Green Belt. In seeking to redevelop the site it would be opened up to greater accessibility and creation of site public open space and the provision of new footways and cycleways through the site. The site would therefore have greater accessibility than it currently offers.
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In light of the case presented above about the need to release Green Belt land to meet the Council’s housing need, particularly in light of the wider issues in the HMA and the inability of other authorities to meet their housing needs in full Barberry consider that there are exceptional circumstances to consider the release of land from the Green Belt. As it stands, the Plan is effectively stating that adjoining authorities will have to release land from the Green Belt to meet Dudley’s needs or that if Green Belt is not released needs will have to go unmet.
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An initial ecological survey had been undertaken which did not identify any significant constraints that would prevent the development of the site. The site is of such a size that it is considered feasible that biodiversity net gain could be delivered on site without impacting on any protected species.
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In respect of agricultural land, this has not been assessed at present so it is not clear if the objections of the loss of Grade 2 and 3 quality agricultural land are founded or not. Either way, Barberry’s view is that the need to accommodate the Borough’s housing needs outweighs the loss of agricultural land.
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Issues relating to noise, air quality and light pollution are matters that can be controlled during the construction process and through the detailed design of the end scheme. As such we do not agree that they are in principle reasons that would prevent the development going ahead.
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The development of up to 533 houses would have significant economic local benefits in terms of construction jobs during the construction phase as well as the use of goods and services in the local vicinity and the wider area involved in the construction of the dwellings. Furthermore, during the construction process local shops and services would benefit from the construction workforce in the area. Following the completion of the development local shops and services would benefit through additional footfall and resident population in the vicinity of the facilities. It is a generally well regarded principle that a residential development would have significant economic benefits to the area. Furthermore, instead of impacting adversely on house prices the development can have a positive impact on a local area albeit that this is not a legitimate planning consideration.
•In respect of the impact on Kingswinford the proposed allocations in and around Kingswinford are as a result of available land rather than necessarily needing or wanting to direct too much development to this part of the Borough. Clearly, the area is attractive to local residents and would provide the opportunity to deliver much needed family housing particularly larger 3 and 4 bedroom properties where the demand in the Borough lies.
•The emerging Local Plan has a brownfield first strategy albeit that in promoting such a strategy it is unable to identify sufficient land to meet its housing need in full. As such, if the full housing needs of the Borough are to be met then some greenfield land is required in order to meet this. The brownfield first approach will not result in the housing needs of the Borough being met hence why we are promoting a greenfield site as a proposed housing allocation.
•In respect of the other matters including flood risk, global warming, heritage, landscape and general design considerations these are matters that we consider could be dealt with through the planning application process and would not present an in principle reason as to why the site should not be allocated.
In light of the above, the objections raised to the inclusion of the site in the Preferred Options Black Country Plan are matters that do not present an in principle objection to the development of the site. Whilst clearly there was a significant level of objection to the draft allocation and the matters raised are in Barberry’s view capable of being addressed through the allocation and planning application process.
Notwithstanding the above, the site had been identified as having an indicative capacity of 533 dwellings, with a policy compliant level of affordable housing which would make a significant contribution to addressing the identified shortfall in housing in the Borough. The delivery of affordable housing being a significant benefit of releasing Green Belt sites, due to the abnormal costs associated with delivering the previously developed sites that make up nearly the entire supply identified by the Council.
Barberry is the sole promoter of the Site and have an agreement with the landowner to bring the Site forward for development. As an experienced developer and promoter. once allocated, planning permission would be sought, and once obtained the Site would be brought to the market and disposed of. The Site has already attracted interest from housebuilders indicating that it is an attractive proposition and would be capable of delivering houses early in the plan period. We wish to reiterate that, the Site remains deliverable, achievable, and suitable, and we recommend it to you as a draft allocation in the draft Plan.
We now turn to the draft plan and the vision, objectives and policies within it.
The Vision for Dudley Borough by 2041
The Vision for Dudley sets out a number of areas that the Council wish to see achieved through the delivery of the Local Plan. These include making Dudley an attractive and desirable place to live, work and visit, having strong, inclusive resilient and thriving communities which enhance health and social wellbeing and providing a wide range of housing that will meet people's needs through their various life stages and is affordable to live in. We are generally supportive of the Vision in that it is aspirational and seeks to deliver the development needs of its residents over the Plan Period. We particularly welcome the intention to deliver a wide range of housing that will meet people's needs.

Comment

Representation ID: 303

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

The Vision for Dudley Borough by 2041
The Vision for Dudley sets out a number of areas that the Council wish to see achieved through the delivery of the Local Plan. These include making Dudley an attractive and desirable place to live, work and visit, having strong, inclusive resilient and thriving communities which enhance health and social wellbeing and providing a wide range of housing that will meet people's needs through their various life stages and is affordable to live in. We are generally supportive of the Vision in that it is aspirational and seeks to deliver the development needs of its residents over the Plan Period. We particularly welcome the intention to deliver a wide range of housing that will meet people's needs.

Comment

Representation ID: 304

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Objectives and Strategic Priorities
Table 4.1 sets out the Council's strategic objectives and priorities. We note Objective 1 is the conservation and enhancement of a natural and built environment including the strategic priority of addressing the climate and ecological emergency. We also welcome Strategic Priority 4 of fostering economic growth and investment and Strategic Priority 6 of creating thriving neighbourhoods by providing new and affordable homes in range of sizes, types and tenures to meet the Borough’s housing needs. Similarly, we welcome Strategic Priority 7 that seeks to deliver the resources, infrastructure and services to support growth.

Object

Representation ID: 305

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

DLP 1 Development Strategy
Policy DLP 1 sets out the Council's targets for the delivery of new homes and employment land. In respect of new dwellings 10,876 new homes are proposed along with the development of at least 25 hectares of employment land. Barberry have significant concerns about the proposed development strategy and specifically around how the Council intends to meet its housing needs over the Plan Period. We also have similar concerns in respect of how its employment land needs will be met and we set out our detailed comments on these points below.
In respect of the Borough’s housing target the policy sets out that the Council will deliver at least 10,876 net new homes over the Plan Period. Paragraph 5.12 confirms that the local housing need for the Borough is in fact 11,954 homes as calculated by the Standard Method. Paragraph 61 of the Framework confirms that Councils should use the standard method as the starting point for establishing a housing requirement for the area. It goes on to state that there may be exceptional circumstances that justify an alternative approach to assessing housing need. The Council are not claiming that there are exceptional circumstances that warrant divergence away from the use of the standard method. As such, it must be concluded that the housing requirement is 11,954 dwellings. However, the Plan identifies a shortfall of 1,078 homes that are required but where sufficient capacity within the Borough to accommodate has not yet been identified.
Having identified what the housing need is in the Borough, the Council undertook an assessment of different options for growth as described in Table 1 of the Dudley Local Plan Options to Preferred Strategy paper (October 2023). The three options tested looked at meeting all or the majority of the Borough’s needs on previously developed land, through urban uplift in regeneration corridors, on low quality open space or elsewhere through duty to cooperate contributions. None of the spatial options considered release land from the Green Belt to meet the Council’s needs. Whilst no doubt the publication of the updated Framework will be used to validate the Council’s approach, it will in Barberry’s view lead to significant housing need going unmet and the associated social and economic impacts that arise from this.
The spatial option that the Council have decided to pursue (Option 3) seeks to focus on meeting the development needs of the Council on previously developed sites within the urban area, use of low quality open space and through duty to cooperate discussions meaning that the Council will be looking to the other authorities in the HMA to accommodate its unmet need of 1,079 dwellings. Barberry object to this approach and do not consider it sound.
If the 1,078 dwellings are to be accommodated in adjoining authorities this would likely result in those authorities immediately adjoining Dudley, which also have significant areas of Green Belt, having to release land from their Green Belt in order to meet Dudley’s needs. If land has to be released from the Green Belt in order to meet the development needs it is Barberry’s view that Dudley should be looking at opportunities within its own administrative area first, including land in its Green in order to accommodate this, before looking to its adjoining neighbours. If adjoining authorities take the same viewpoint as Dudley and decide that they also do not need to release land from the Green Belt, housing needs arising from Dudley and across the HMA are not going to be met.
The Plan, nor the Dudley Local Plan Options Preferred Strategy paper, does not elaborate on the Council’s decision not to release land from the Green Belt to meet its needs particularly when the Plan highlights that there is a shortfall of what is needed against what land is available to accommodate this need. Barberry consider this to be a short-sighted approach particularly when land is available albeit it is in the Green Belt, which could help meet the Council's housing needs over the Plan Period. This point is particularly pertinent when under the Black Country Plan Preferred Options version, the Council had proposed to release land from the Green Belt to meet the Council's needs as well as the unmet needs arising in the wider Black Country authorities. Again, the Plan does not provide clear or sufficient justification for the decision of the Council not to release land from the Green Belt nor why this unmet need should be met elsewhere when there is sufficient suitable land available within the Borough to meet these needs. Furthermore, whilst the updated Framework does not require Green Belt to be reviewed, it does state that it can still be reviewed in exceptional circumstances. Barberry contend that exceptional circumstances exist that warrant a review of the Green Belt. These include:
•worsening affordability as demand outstrips supply,
•worsening delivery and provision of affordable housing,
•increased homelessness
•Worsening overcrowding and living conditions,
•Increased pressure on private rental sector with associated issues of unsecure tenancies and susceptibility to rent increases,
•Increasing ageing population with resultant increase in demand on social and health care services,
•economic impacts on the working age population as those adults who are able to work may not have suitable accommodation to live in thus resulting in increased commuting distances, worsening impacts on congestion and air quality, and
•the inability to attract workers into the HMA could have significant repercussions for the wider economy if the right type of houses are not available for those wanting to live and work in the conurbation.
The land at Swindon Road, Wall Health, Kingswinford was identified as a draft allocation in the Black Country Plan Preferred Options as a strategic housing site capable of accommodating 533 dwellings. Clearly at some point, the Council considered that the Site was suitable to accommodate residential development sufficient for it to be identified as a draft allocation. The Site was considered suitable and deliverable and Barberry remain of the view that it should be included as a draft allocation in the Plan. In allocating the land at Swindon Road, Wall Heath, it could potentially reduce the shortfall in housing that is required but unable to be currently accommodated in the Borough by approximately half. We set out below why we consider that the Site is suitable for development and why it should be allocated as a site for housing in the Borough Plan.
In addition to the shortfall in housing land that the Borough Council is currently unable to accommodate there is also a shortfall in the amount of employment land that is needed but which sufficient land has not been identified in order to accommodate the employment requirements going forward. Paragraph 5.12 confirms that the EDNA establishes a need for 72 hectares (98 hectares including replacement of employment land losses) of land for employment development although there is an anticipated supply of just 25 hectares resulting in a shortfall of 47 hectares (increasing to 73 hectares if including replacement of employment land losses). The Plan goes on at paragraph 5.13 to confirm that unmet employment land need will be provided across the Greater Birmingham and Black Country HMA, the Functional Economic Market Area (FEMA) and other areas with which the Borough has a physical or functional relationship. The Council is, therefore, looking to accommodate its housing and employment needs outside of its administrative area via agreeing with adjoining authorities for them to make land available to meet Dudley’s needs. Barberry do not consider this to be a sound approach for similar reasons as to those set out above in respect of meeting its housing needs. Barberry contend that Dudley has suitable land available within its own administrative area albeit it is in the Green Belt and that the Council should be considering the suitability of this land for development first rather than asking its neighbouring authorities to meet its needs and potentially to release land from its Green Belt in order to do so.
The issue of unmet housing need arising across the HMA and how this will be addressed is a key issue that the Plan will need to address. . Whilst the Dudley Local Plan identifies a relatively modest shortfall in housing land there are wider issues specifically arising in Sandwell that may compound the issue of where and how housing need is met. Sandwell Council is also currently consulting on its Preferred Option Local Plan which identifies a shortfall of 18,606 dwellings that the Council need but which are unable to accommodate within its own administrative area. The Council will also be looking to its adjoining neighbours, of which Dudley is one, in order to see whether their need can be met outside of its administrative area. Furthermore, the consultation on the Birmingham City Issues and Options that concluded in December 2022 also highlighted that it too has a housing shortfall of approximately 78,415 dwellings that will also need to be met elsewhere within the HMA. Dudley in seeking to meet part of its unmet need by reaching agreement with adjoining authorities in the HMA will to a degree be competing with other authorities that also have a much more significant shortfall to meet and which have less land, including Green Belt land to meet this. This reinforces Barberry’s view that the Council should be doing all it can to meet its needs in full in its administrative area even if it means releasing land from the Green Belt to do so. By meeting all its development needs within Dudley this would reduce the wider pressures within the HMA on other adjoining authorities to help meet the unmet needs arising principally in Sandwell and Birmingham but also potentially in Wolverhampton City as well.

Support

Representation ID: 306

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 2 Growth Network : Regeneration Corridors and Centres
Barberry generally welcomed the strategic approach for the growth network including the focus on development within existing urban areas and regeneration corridors. In respect of the regeneration corridors, we note that regeneration Corridor 1 Pensnett Kingswinford has a strong strategic employment area and a network of busy local centres. Furthermore, the corridor has hosted residential development on former employment areas previously and has the potential to increase investment in the Pensnett Estate. A potential opportunity at Ketley Quarry is identified as a priority site. In respect of the vision to 2041 we agree that the corridor has the potential to provide high quality residential areas with access to recreational areas, transport network, key services and centres along with employment opportunities. Directing further development to regeneration corridor would help with delivering the overall vision for the Local Plan.

Object

Representation ID: 308

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 3 Areas Outside the Growth Network
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 11,954 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.

Support

Representation ID: 309

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 4 Achieving Well Designed Places
Barberry generally support the objectives of the policy in terms of ensuring new development is of high quality and well designed, recognising that this would have a positive impact on a character of the Borough as well as future residents and occupiers of new development. Barberry also recognise that design has a key role to play in achieving sustainable development by responding to known constraints and delivering high density development that makes effective use of previously developed land. The role of design in new development is, therefore, key in delivering a wide range of policy objectives set out in the Plan.

Support

Representation ID: 310

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 6 Infrastructure Provision
Barberry support the intention that all new development should be supported by the necessary on and off site infrastructure to serve the needs of those occupying new development. In providing new infrastructure to meet the needs of future residents the request to fund them must ensure that the resulting development is viable and that the development can support the requirements being requested.

Comment

Representation ID: 311

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 8 Health and Wellbeing
The policy requires that residential developments of 150 dwellings or 5 hectares will be required to provide a Health Screening Impact Assessment as part of the planning application. Barberry acknowledge that significant residential development such as that being promoted at the Triangle site in Kingswinford, has the ability to make significant contributions to the health and wellbeing of new and existing residents alike. This can be principally through the provision of areas of public open space and recreational amenities on site, including measures to make active travel by the provision of new footway and cycleway and the provision of on-site facilities such as new allotments or community orchards. These measures would not all be possible on previously developed sites within urban areas and, therefore, the benefits of identifying larger strategic greenfield sites, such as the Triangle site, could actually have a positive impact on the health and wellbeing of residents for the Borough.

Comment

Representation ID: 312

Received: 21/12/2023

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Policy DLP 9 Healthcare Infrastructure
Barberry acknowledge that in new residential development there may be a requirement to mitigate the impact of the development by providing additional healthcare infrastructure where there is an increase in demand on this. This can, however, be mitigated through the provision of additional capacity of existing GP surgeries or through the creation of new facilities secured by developer contributions of CIL as part of the planning application process. Clearly any obligations or contributions arising through new development would need to ensure that the development remains viable in order to deliver these and would need to be considered as part of an overall package of measures and policy aims to be set out in the Plan.