Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 617

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: CBRE Limited

Policy DLP1 (Development Strategy)
Brockmoor Properties Limited support the development strategy set out in Policy DLP1, to deliver the identified development requirements sustainably. It is agreed that the majority of development should be delivered within the urban area, and identified Centres and Regeneration Corridors. Brockmoor Properties Limited further support the proposed distribution of growth set out in Table 5.1, more specifically to deliver 854 new homes in Regeneration Corridor 2, where the sites are situated, over the Plan period. It is important that overall development requirements are clearly set out as a minimum and this wording should be retained and reflected throughout the document.

It is also agreed that new homes should be supported by jobs and local services. The Brockmoor Foundry sites are located within well-established neighbourhoods and are well-connected to employment areas, local services and the Strategic Centre of Brierley Hill.

Comment

Representation ID: 618

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: CBRE Limited

Policy DLP2 (Growth Network: Regeneration Corridors and Centres)

The Brockmoor Foundry sites are located within a Regeneration Corridor, identified as the primary focus for new development, regeneration and infrastructure investment. As set out in the response to policy DLP1, it is agreed that Regeneration Corridors should be a focus for sustainable growth.

Part 3 should recognise that within the Regeneration Corridors, housing development should come forward as a mix of sized sites to ensure consistent delivery over the plan period, which will come together to achieve the strategy, including allocated and windfall sites. We recognise the need to strike a balance between the protection and enhancement of sustainable employment land and the releasing of brownfield land for housing delivery. We are supportive of the Council's approach to allocate underused employment land that would not be suitable for a modern occupier and therefore making efficient use of the land for housing delivery, as per Paragraph 119 of the NPPF.

Support

Representation ID: 619

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: CBRE Limited

Policy DLP10 (Delivering Sustainable Housing Growth)

Brockmoor Properties Limited support the policy requiring 'at least' 10,876 net new homes over the plan period, with the majority to be delivered through existing permissions or allocations within the Plan. Whilst the Brockmoor CBRE 2Foundry sites' have draft housing allocations , we consider that the policy should also recognise the role of Regeneration Corridors and other urban areas as locations appropriate for housing development as set out in Policies DLP1 and DLP2.

Support

Representation ID: 620

Received: 20/12/2023

Respondent: Brockmoor Properties Limited

Agent: CBRE Limited

Policy DLP11 (Housing Density, Type and Accessibility)

In principle, Brockmoor Properties Limited generally support Policy DLP11 (Housing Density, Type and Accessibility), however the draft policy as currently worded could be clearer and more effective for future residential development proposals.

The draft policy promotes flexibility over the plan period for housing types to be assessed on a site-by-site basis which is important in the dynamic housing market and specific locational requirements. Part 2 of this draft policy however, states that the range of house types and sizes should be 'in line with the most recently available information' and provides no further information within the policy itself as to what this could constitute. For this policy to be prepared in accordance with Paragraph 16 of the NPPF (2021) the following text should be inserted into part 3 (underline shows suggested insertion):

"Developments of ten homes or more should provide a range of house types and sizes that will meet the accommodation needs of both existing and future residents, in line with the most recently available information, such as:
The Black Country HMA 2021 (or any subsequent revision);
or Detailed Local Housing Market Assessments (where applicable);
or Current and future demographic profiles;
or Locality and ability of the site to accommodate a mix of housing;
or Market signals and local housing market trends."

Additionally, paragraph 8.14 of the policy supporting text, provides a Table showing the housing tenures which refers to a housing mix informed by the Black Country Housing Market Assessment (HMA) 2021. The justification follows on to state that "It is important that housing provision reflects the needs of these new households, allowing for at least one bedroom per person, whilst also reflecting the varying needs set out in the HMA", This is not however referred to in the policy wording itself nor does the HMA provide evidence that Dudley MBC will be undertaking a further HMA assessment specific to the authority area. This makes the policy ambiguous as it is not clear what evidence Developers should rely on in designing residential schemes.

The policy and supporting text need to be clear about which evidence is to be used to inform housing mix and the wording suggested above would assist in removing ambiguity in the policy. Paragraph 8.14 should be reworded to be clearer or omitted if it conflicts with the requirements of the policy.