Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 463

Received: 19/01/2024

Respondent: CPRE West Midlands Group

Not in a position to comment on environmental policies in detail. However, we support in general the aspiration to protect the key green and blue infrastructure in the district.

Comment

Representation ID: 464

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE generally support Policy DLP 11 on Densities, and consider the standards set out in Para 3 appropriate. However, we think the Policy should also require developers to show that they have sought to make the most efficient use of land within a sustainable design approach, as some densities may comfortably be higher than these minima.

Support

Representation ID: 465

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE generally supports the reallocation of employment land for housing where the land is not needed for employment use and there is a good case for doing so.

Support

Representation ID: 466

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE supports the general approach to centres including the potential for some repurposing including residential development (Part 1) and upper storey residential accommodation (Part 5 (VII))

Comment

Representation ID: 468

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE generally supports this policy approach to residential housing in centres. However, as well as considering adverse impacts which need avoiding, the policy should stress the potential sustainability of such sites and the role they can play in supporting the viability and vitality of a centre.

Object

Representation ID: 472

Received: 19/01/2024

Respondent: CPRE West Midlands Group

Housing
West Midlands CPRE objects to the housing supply figure give in Policy DLP 1, 1a, We consider it is too low and that Table 5.1 should be reviewed to take account, in particular, of large windfalls.

We commissioned a review of the housing need and supply (attached) which suggested that 1,019 homes, at a minimum, should be added to the supply to give a more realistic windfall allowance, including some housing from employment sites (in line with Policy DLP21/22) and in town centres (in line with Policy DLP 24/28) which could reasonably be expected over the next twenty years.
We consider some further additional supply could be added based on higher densities as well as reducing the discount rate on industrial sites.

That would mean total supply in Table 5.1 would be at least 11,895 (59 short of the current requirement, but below the current (unneeded) 5% buffer).

This would ensure that even under the Standard Methodology approach espoused by the council there would be sufficient housing to meet the anticipated need and the addition imposed by the Government to meet the ‘affordability uplift’.

However, we consider that there is a case for adopting a figure closer to lower the ONS2016 housing projections. While the CENSUS shows higher base-level housing numbers for Dudley, across the Black Country the CENSUS results level out closest to the ONS2016 need. In other words, viewing the need across the sub-region in a holistic way, would suggest a common approach to each local authority to avoid double-counting and would, in our view, be justifiable under the new provisions of the NPPF (December 2023 Para 61).

That would mean total need in Table 5.1 would be at least 9,306 (without the unneeded 5% buffer). That would give an excess in Dudley of 2,589 without further release in the Green Belt which could allow for adjacent housing shortfalls (particularly in Sandwell) to be accommodated within the Dudley allocations.

Comment

Representation ID: 476

Received: 19/01/2024

Respondent: CPRE West Midlands Group

No allowance for larger employment land windfalls, even though the cross-boundary BC evidence suggests that could be an important source in the borough. A further 14 has is considered to be specifically related to Dudley from the WMRFI.

Commissioned a review of employment need and supply (attached), which concludes that this figure does not fully account for already identified land in South Staffordshire, including at the WMRFI, and that supply would will in reality meet that outstanding need.

Comment

Representation ID: 477

Received: 19/01/2024

Respondent: CPRE West Midlands Group

We do not agree with the policy wording on Duty to Cooperate in Part 3 of the Policy. We consider that the needs of Dudley for employment land should be viewed in the context of the Black Country itself and the policy should identify that any shortfall of employment land will be met in other parts of the sub-region.
In terms of housing, we do not consider there is a justified short-fall, but any excess housing within the current allocations should be identified as meeting a short-fall in other Black Country boroughs, notably Sandwell.
This would mean that Para 5.13 should also be redrafted to stress that the need should be met within the Black Country sub-region, and perhaps Birmingham, not the wider GBBCHMA or the FEMA.

Comment

Representation ID: 479

Received: 19/01/2024

Respondent: CPRE West Midlands Group

West Midlands CPRE strongly support the protection and enhancement of Green Infrastructure and the maintenance of Green Belt boundaries as well as the emphasis on providing development in sustainable locations as set out Parts 4, 5 and 6 of Policy DLP 3.

Object

Representation ID: 480

Received: 19/01/2024

Respondent: CPRE West Midlands Group

West Midlands CPRE objects to this Policy in line with our objection to Policy DLP 1. We consider there is additional housing supply as set out in the attach report which we commissioned. This would include, in particular a higher level of windfalls in Table 8.1 and create a supply of at least 11,895.