Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 338

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

Table 6.1 Dudley Housing Allocations

Land North of Sandyfield Road, Sedgley

The promotion site has not been assessed in the SHLAA but forms part of a wider parcel (BL10) in the Black Country Green Belt review. We consider this needs to be rectified.

Not clear why green belt sites have been excluded in this review considering Dudley cannot meet its housing target and limited capacity of surrounding authorities. Plan is unsound as is.

Comment

Representation ID: 339

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

The promotion site has been considered in the SHLAA as shown in the SHLAA map extract (2021/22)3 where the part of the site that falls into Dudley. We see this as an error and the site must be assessed.

Comment

Representation ID: 340

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

EVIDENCE BASE

There appears to be little in the way of up to date or new evidence supporting the Reg 18 Plan at the moment. We can only assume that much of it is therefore based on the evidence used to prepare the previous Black Country Plan.

Comment

Representation ID: 341

Received: 21/12/2023

Respondent: Seven Homes

Agent: RCA Regeneration Ltd

SUSTAINABILITY APPRAISAL

Green belt sites should be included in the SA.

SA sets out that Option 3 has been chosen because it would address housing need through a ‘balanced spatial approach’. We do not agree with this. Firstly, it is not addressing housing need – the council will still be left with over a thousand houses to find. Secondly, we consider the balance is simply not there, particularly as the focus on brownfield will not deliver the required affordable homes needed in the Borough, for reasons we have already given.

Para 8.4 in the reasoned justification for Policy DLP10 (Delivering Sustainable Growth) sets out that 90.98% of current local housing need up to 2041 (homes) with 96.4% of the supply on brownfield land and 3.6% of the supply on greenfield land. This is not balanced at all. How many of the brownfield sites that form part of the 90.98% have been previously allocated for housing? How many have had previous planning permission which have lapsed or stalled? Have the council objectively gone through all of these sites and removed those which do not have a realistic chance of delivery?

Finally, we note that the SA identifies that the true impacts of the unmet need, which is being exported, cannot be fully assessed. Access to employment opportunities, as well as environmental/social impacts cannot be assessed because it is not known where these homes will be located. The SA is clearly incomplete because the strategy is flawed.