Part Two: Centres and Site Allocations (Regulation 18)

Object

Representation ID: 363

Received: 12/12/2023

Respondent: Harworth Group

Agent: Claremont Planning Consultancy

Regulation 18 Dudley Local Plan Part Two: Site Allocations
9.1.
Part Two of the Reg.18 Local Plan identifies the housing and employment allocations within the Borough. The land under the control of Harworth Group off Thorns Road, Brierley Hill is proposed to be allocated under site reference DLP H017, with an indicative housing capacity of 184 dwellings identified. The allocation of this site is strongly supported by Harworth Group, who intend to bring forward the entire site extent for development. The commitment of Harworth Group to the delivery of this site allocation is evidenced by the development proposals currently under consideration through application P22/1363 which seeks consent for 50 dwellings on land comprising the southernmost parcel of the wider allocation.
9.2.
The land off Thorns Road is currently allocated through the adopted Local Plan under site reference H13.17 with this allocation proposed to be carried forward through the Local Plan Review. However, draft allocation DLP H017 proposes to exclude an existing car park and industrial unit from the extent of the existing site allocation and instead envelops this to include the industrial unit currently occupied by WHS Plastics within the allocated site, alongside the land to the south currently the subject of a planning application P22/1363. The extent of proposed site allocation DLP H017 conflicts with the extent of land currently allocated for residential development through the adopted Local Plan under reference H13.17. Adopted Local Plan allocation H13.17 includes the land currently the subject of application P22/1363, the adjacent car park, and the Sunrise Medical and WHS Plastics industrial units to the north. Moreover, the adopted Dudley Borough Development Strategy allocated site H13.17 for the delivery of 231 dwellings between 2016-2026. The amended allocation extent proposed through the draft Local Plan is not supported whereby the amended proposals would reduce the capacity of the allocated site by almost 50 dwellings. The challenges presented to housing delivery, not only within Dudley Borough, but throughout the West Midlands area are well documented and indeed are recognised by the Council within the draft Local Plan. The proposed reduction in the allocated site extent at Thorns Road, and the implications of this on the capacity of the site to deliver new residential development, in the context of a housing shortfall cannot be supported and fundamentally conflict with the Framework’s requirement for Local Plans to provide a positive and justified strategy to meet the development needs of the Borough.
9.3.
Furthermore, the Council have failed to provide any justification for the proposed reduction in the extent of land allocated at Thorns Road. As evidenced by application P22/1363 which is currently under consideration by the Council, Harworth Group are actively progressing with their proposals to deliver the full extent of land currently allocated under the adopted Local Plan H13.17. With respect to
allocated sites which are subject to live planning applications, it is maintained that the Council should have sought to engage with Harworth Group and adjacent landowners prior to making any amended to the allocated site extent. The majority of land proposed within the Reg.18 Plan to be excluded from the allocated site extent is subject to leases which will expire within the first five years of the Plan period. The remainder of the land is subject to leases that will expire in the later years of the Plan period and therefore will become available for development prior to 2041. The extent of land proposed to be allocated under DLP H017 should therefore be reconciled to reflect that currently allocated under H13.17 of the adopted Local Plan, whereby it remains that the existing allocated site extent is suitable, available, and deliverable within the Plan period through to 2041. In this respect, it should be recognised that delivery of this allocation can make an immediate contribution towards housing delivery in the Borough, as evidenced by current application P22/1363, whilst later phases of the development will assure housing delivery in the medium and long term through to 2041. Therefore, it remains Harworth Group’s intention to bring the entirety of the site extent currently allocated under reference H13.17 of the Local Plan forward for development, and this should be supported by the Council and the discrepancy in the land proposed to be allocated under DLP H017 reconciled to address this.