Part One: Spatial Strategy and Policies (Regulation 18)

Comment

Representation ID: 481

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE supports Part 1 and 2 of this Policy but consider the reference to ‘an evidenced functional economic link’ unhelpful in Part 3 as it suggests that further employment land could be sought in South Staffordshire (and other more rural districts) rather than in the Black Country itself even though the evidence (as set out in our objection to DLP 1 and the attached report) suggests there is sufficient Black Country urban land to meet those needs.

Paragraph 3 should also be changed to emphasize the primary role of brownfield land in Birmingham and the Black Country in meeting any additional housing need rather than other authorities, although I consider that Dudley has identified enough land that it should be able to identify some of that as meeting neighbouring authorities’ needs, and in particular Sandwell.

Comment

Representation ID: 482

Received: 19/01/2024

Respondent: CPRE West Midlands Group

CPRE West Midlands supports Policy DLP 42, as far as it goes, but it is deficient in that it fails to deal with energy generation, particularly where it is (and is not) appropriate to locate large solar arrays. It is our view that the right place for this is on rooftops and brownfield land, not on green field and certainly not on Green Belt land. The plan should contain a policy to this effect. See CPRE Rooftop Revolution Report (attached) on this subject.

Support

Representation ID: 483

Received: 19/01/2024

Respondent: CPRE West Midlands Group

WM CPRE strongly supports the protection of Dudley’s Green Belt. In line with our comments on Policies DLP1, 10 and 18 we do not consider there is any justification for releasing Green Belt in Dudley or for seeking Green Belt releases in adjoining districts to meet development needs in Dudley.

Our view on this is strengthened by the provisions of the new NPPF, published in the final days of this consultation.