Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 442

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

The Vision for Dudley Borough by 2041
The Vision for Dudley sets out a series of aspirations 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.

The development of my clients land interests to the north of Stourbridge town centre will directly contribute towards this objective. It will deliver high quality new homes and office space on redundant brownfield land.

Support

Representation ID: 443

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Objectives and Strategic Priorities
Table 4.1 sets out the Council's Strategic Objectives and Priorities. Objective 1 is the conservation and enhancement of the natural and built environment including the strategic priority of addressing the climate and ecological emergency. We agree with this approach. This can best be achieved by directing development to brownfield sites in sustainable locations. We also welcome Strategic Priority 6, creating thriving neighbourhoods by providing new and affordable homes in range of sizes, types and tenures to meet the Borough’s housing needs. My client’s proposal for the redevelopment of their land interests to the north of Stourbridge town centre will directly deliver this objective.

Comment

Representation ID: 444

Received: 13/12/2023

Respondent: Revelan Developments Ltd

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. Revelan have some concerns with the proposed development strategy and specifically around how the Council intends to meet its housing needs over the Plan Period. Policy DLP 1 advises 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 11,954 homes as calculated by the Standard Method. There is an identifies a shortfall of 1,078 homes due to a lack of suitable housing sites. 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 meeting the Borough’s housing needs on previously developed land through urban uplift in regeneration corridors, on low quality open space and elsewhere through duty to cooperate.
Revelan support the approach of focusing development on previously developed land.
However, the draft Plan suggests that there will be a housing shortfall with this approach. It is, therefore, essential that the Plan seeks to make the best use of previously developed sites supporting higher density development proposals in sustainable locations. Such schemes should not be over burdened with planning obligations to make sure they are deliverable. A flexible approach should be applied to spacing standards and the use of NDDS.

Support

Representation ID: 445

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 2 Growth Network : Regeneration Corridors and Centres
We generally welcomed the strategic approach for the growth network including the focus on development within existing urban areas and Regeneration Corridors. Table 5.3 –
Regeneration Corridors, advises that Regeneration Corridor RC2, will keep its employment focus with strategic employment areas connecting centres, particularly Brierley Hill and Dudley. High quality housing will be focused in centres alongside the corridor with access to enhancing green infrastructure. Opportunities for canal side living in the corridor to Stourbridge, as well as potential local employment areas, will be pursued.

Support

Representation ID: 446

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 4 Achieving Well Designed Places
We 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. We 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. We support the reference to encouraging canal side living.

Support

Representation ID: 447

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 6 Infrastructure Provision
We 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. However, any infrastructure requests must ensure that the scheme remains viable and that the development can support the requirements being requested.

Comment

Representation ID: 448

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 11 Housing Density, Type and Accessibility
Policy DLP 11 specifies the density and type of new housing that should be provided, the type, levels of accessibility and the need to achieve high quality design. The policy requires developments of 10 or more homes to provide a range of house types and sizes and achieve the density target set out within the policy. These range from 100 dwellings per hectare on sites that are within strategic centres or town centres, to 45 dwellings per hectare where a site is accessible and 40 dwellings per hectare for a moderate density housing development. In seeking to achieve the density targets set out above we note the evidence contained in the Black Country Housing Market Assessment (March 2021). This sets out the size of housing required within each tenure within Dudley for owner-occupied, rented, shared ownership or social rented / affordable rented properties. Whilst we support maximising densities in general terms the approach to dwellings mix should not be applied in all instances. For example, Revelan have submitted a planning application proposing the development of 94 dwellings on land to the north of Stourbridge town centre. 48 of these dwellings will be affordable. The mix and size of the properties has been established though working with an affordable housing provider. The scheme is tailored to meet an identified need for affordable housing. Scheme specific circumstances such as this should be taken into account in the application of the policy.

Comment

Representation ID: 449

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 12 Delivering Affordable, Wheelchair Accessible and Self Build / Custom Build Housing
All flatted/apartment schemes should be exempt from self-build and custom build hosing
requirements. It is not possible to have a self-build flat/apartment.

Comment

Representation ID: 450

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 16 Education Facilities
We have no objection to the Council seeking contributions towards education facilities from new development if there is a need, any education contributions sought must also be tested in the context of the other policy requirements that the Plan to ensure schemes remain viable.
Also, it is our view that affordable housing should not attract an education contribution. To qualify for an affordable property an individual/family will be registered with the Council and therefore local to the area. They will not create a demand for additional educational facilities as the residents would have to have a connection to the local to the area and already have school place provision.

Comment

Representation ID: 451

Received: 13/12/2023

Respondent: Revelan Developments Ltd

Agent: Harris Lamb

Policy DLP 32 Nature of Recovery Network and Biodiversity Net Gain
Following the enactment of the Environment Act there is soon to be a statutory requirement to achieve 10% biodiversity net gain through new developments. As this is soon to be a statutory
requirement there is no need to a policy in the Local Plan.