Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 330

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

To meet development needs there is a requirement for a more balanced strategy and one which also includes for more deliverable and needed greenfield sites and assess and review the Green Belt to help identify potential areas of growth in the real context of a significant deficit in the supply of brownfield land within the urban area. The position whereby no Green Belt release is proposed has been arrived at for political rather than planning reasons. There is scant evidence that proper consideration has been given or judgement exercised from a planning perspective as to whether there might be opportunities within the Green Belt better to meet the Borough’s needs. Evidence as to why the full need cannot be met is lacking. This shortcoming is amplified by a lack of any clear evidence at this stage as to the extent to which the Council have, or are likely to, engage with neighbours under the Duty to Cooperate, or how fruitful any such engagement might be. Greenfield and Green Belt sites should be allocated to help meet the need. Policy DLP1 should acknowledge and accommodate this, and consequential changes should be made throughout the DLP (e.g., to Table 5.1, Policy DLP2, Policy DLP10, and elsewhere) to reflect it and allow for a contribution to be made by such sites, rather than excluding them
entirely.

Object

Representation ID: 332

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

As drafted the DLP raises some very serious concerns over its inability to meet Dudley’s minimum housing needs over the Plan period, and by some considerable margin. It simply does not fully grapple with the scale of unmet need it has identified. In doing so it fails to address in any tangible way how the homes needed in Dudley during the DLP period can ever be delivered and fails to meet the tests of soundness set out in the Framework.
1.83 This fundamental concern is exacerbated where those sites that are relied upon in the draft DLP, as set out in its Table 8.1, are unlikely to deliver even the 10,876 net new homes it anticipates over the Plan period, such that the true extent of unmet need within Dudley is likely to be significantly greater than the already substantial 1,078 homes it acknowledges.
1.84 It is exacerbated further still where Dudley’s neighbouring authorities lack suitable growth locations to meet their own needs, or Dudley’s unmet needs, and are in any event constrained heavily by their own Green Belts, such that they would need to release sites within their own Green Belts to meet Dudley’s unmet needs.
1.85 There is also a distinct lack of flexibility to deliver the 10,876 homes identified in Table 8.1 of the draft DLP. This also necessitates identifying additional housing sites to provide flexibility in Dudley’s housing supply over the DLP period.
1.86 With this in mind, it is important to consider that a Green Belt review is a “once in a generation” occurrence and Green Belt boundaries should endure well beyond the Plan period. Despite this, and the inability of the heavily brownfield-centric strategy to meet Dudley’s minimum housing needs being a recurrent strategic planning issue, which requires significant bold intervention, Green Belt release sites are not being considered at all through the draft DLP.
1.87 With brownfield opportunities becoming exhausted, and in any event failing to deliver, the DLP must identify Green Belt release sites to help meet its minimum housing needs during its planned period, and beyond, and to avoid the need for another Green Belt review in the near future.
1.88 The concerns raised above in reference specifically to Policy DLP10 are far reaching and point to a fundamental failing of the draft Plan to meet the tests of soundness set out in the Framework.
1.89 In terms of a remedy for these shortcomings, at a basic level, Policy DLP10 requires amendment to identify significantly more deliverable and developable housing sites and to achieve that Green Belt release sites must be identified.
1.90 However, and crucially, the draft Plan fails to address in any tangible way how the minimum number of homes needed in Dudley during the DLP period can ever be delivered, and this exacerbates the very serious shortcomings within Dudley and the Black Country generally. This is a recurring strategic planning issue and requires significant bold intervention including a step-change in approach to avoid the new homes that are needed in Dudley being unprovided over the DLP period.
1.91 This is a fundamental point. The DLP must do everything possible to meet as much of its minimum requirement as possible within Dudley. It must also demonstrate convincingly how it will ensure any remaining requirement will be taken up. As drafted, it fails resoundingly on both counts.

Object

Representation ID: 333

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

1.92 Concerns are expressed elsewhere in these representations with the way the spatial strategy (Policy DLP1) of the Dudley Local Plan (DLP) is framed, the extent to which at the outset it properly acknowledges the scale and character of development need, the ways it suggests the need can be met, and the requirement to identify additional development land for housing including through Green Belt release. Those concerns are expanded in some detail in terms of policy around housing delivery (Policy DLP10), again making the point that additional development land is needed including through Green Belt release.
1.93 Those concerns have consequential effects throughout the DLP which should be accommodated. Those effects are notable in relation to Policy DLP49. The Green Belt should be assessed and reviewed such that the most suitable sites for development can be identified and allocated, and development needs can be met, in circumstances where the current excessive focus on urban cramming is inadequate and will not succeed. Persimmon Homes have promoted land at Holbeache Lane for residential development including its removal from the Green Belt to provide a deliverable site to meet housing needs. IT was removed from the Green Belt and allocated for housing in the previous draft review of the Black Country Plan – its merits for removal from the Green Belt and allocation for housing remain to this day. The attached Vision Document sets out the merits of the site and justifies its removal from the Green Belt and allocation for housing.

Object

Representation ID: 334

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

1.94 It is helpful that Policy DLP32 acknowledges (part 1a) that development is permissible in the Local Nature Recovery Network (LNRN) including in circumstances where it will deliver benefits appropriate to the zone in which it is located. However, the phrasing of the draft policy is somewhat confusing in circumstances where part 1 refers to all development, and part 1a refers to the location of the development within the LNRN, but not all development will be within the LNRN. This might be remedied by adding the words, “if located within the Local Nature Recovery Network” to the beginning of part 1a of the policy.
1.95 Part 5a of the policy should allow for BNG to be delivered through measures outside Dudley where this is most appropriate. This might include, for example, schemes at or close to the edge of the borough boundary where more important gains can be made through interventions in the neighbouring authority. Part 8 of the policy allows for the potential for measures to be local to the development site – there will be circumstances where this best and most appropriately means land in a neighbouring authority, and that should be supported by the policy.

Object

Representation ID: 335

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

1.96 Policy DLP60 identifies Areas of High Historic Landscape Value and states the Council will resist any development or other works taking place which would be detrimental to the character, quality and historic integrity of the landscape. Further it states that the Council will seek to protect and enhance views into, from or within Areas of High Historic Landscape Value. Approval will not be given where such views would be unduly interrupted or harmed, or where the opportunity to enhance such a view would be lost. In conjunction with Policy DLP55, it essentially seeks to identify these areas as non-designated heritage assets. The policy is objected to. The areas of land identified in the plan are extensive and so broad as to not properly identify their significance. Further the policy affords levels of protection which are excessive, not only applying to the land identified but adjoining land and view to and from the identified AHHLV. They effectively amount to a blanket protection of all development on or anywhere near these identified areas which seems unreasonable, especially given the extent of land which they effect in the Borough.

Object

Representation ID: 863

Received: 21/12/2023

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Persimmon
Homes have promoted land at Holbeache Lane for residential development including its
removal from the Green Belt to provide a deliverable site to meet housing needs. IT was
removed from the Green Belt and allocated for housing in the previous draft review of the
Black Country Plan – its merits for removal from the Green Belt and allocation for housing
remain to this day. The attached Vision Document sets out the merits of the site and
justifies its removal from the Green Belt and allocation for housing