Part Two: Centres and Site Allocations (Regulation 18)

Object

Representation ID: 566

Received: 15/12/2023

Respondent: Dudley Group NHS Foundation Trust

Agent: Claremont Planning Consultancy

Policy DLPLGS1 - Corbett Meadow Local Green Space

9.1. The Dudley Group NHS Foundation Trust and Charles Church Homes strongly object to the proposed designation of Corbett Meadow Local Green Space through draft Policy DLPLGS1 of the emerging Local Plan. The Council previously sought to secure such a designation on the site through the Black Country Plan Review, prior to the decision to withdraw from the preparation of the joint Plan and instead proceed with the Dudley Local Plan Review instead. Representations were accordingly submitted on behalf of both parties strongly objecting to this proposal, as well as demonstrating why the proposed designation was not consistent with national policy.

9.2. It is maintained through these representations that the proposed designation of the site continues to be inconsistent with the requirements of national policy for such designations. The Framework identifies at Paragraph 101 that ‘Designating land as Local Green Space should be consistent with the local planning of sustainable development and complement investment in sufficient homes, jobs and other essential services’. It is considered that the designation of Land at Corbett Hospital is not consistent with the requirement for the emerging Plan to contribute towards achieving sustainable development, and in particular deliver sufficient housing to meet objectively assessed needs. It is therefore considered that the Council should reconsider the proposed designation and recognise the potential for the site to accommodate some housing delivery alongside public open space and biodiversity enhancements, such that it would provide a contribution towards achieving sustainable development in the Borough.

9.3. It is noted that the within the policy itself and the supporting text is consideration of the history of the site, including reference to grounds to be used for a public park. The Policy and supporting text however fail to acknowledge that since the land was originally gifted in the late 19th Century, the ownership of the land as part of a wider parcel transferred to the NHS on its formation in 1948, with part of the wider site continuing to be in medical use today. Other parts of the wider site were already disposed of by the NHS previously, which now forms the residential street John Corbett Drive. Notably, the NHS has no obligation to provide public access for recreation to any parts of the wider site, and instead the land proposed to be designated through this policy is
being utilised for agriculture at the present time. This land has been identified by the NHS as not required for medical purposes and was therefore identified as surplus to requirements. It is therefore to be disposed of in accordance with public sector land disposal policy set by the Government on a national basis, as referenced in the earlier representations to the Health and Wellbeing section of the Plan. It is considered that the proposed designation as Local Green Space is sought to prevent development from taking place on the site, and the NHS from being able to receive ‘best value’, such that it is not consistent with national policy aims of achieving sustainable development. Importantly, there was no obligation on the NHS to provide public access to or use of the land proposed to be designated through this policy, and this should be reflected in the policy and supporting text, confirming that no public park is present on the site in order to ensure that it is consistent with the tests of soundness and justified, based on proportionate evidence.

9.4. It should be recognised that at present there is no public access to the site, and as noted above it is currently in agricultural use. Designation of the site as a Local Green Space would not impact this, or secure public access. The Planning Practice Guidance confirms that public access is not a prerequisite for designation of Local Green Spaces, however designation itself does not confer any rights of public access over what exists at present. Accordingly, access must be sought through separate negotiations with the NHS Trust, as landowners, which is not feasible at present due to the ongoing agricultural use of the land. Through the proposals for development on the site advanced through P22/1050 however, more than half of the site was to be dedicated to public open space and green infrastructure. This would have delivered a new public park and area of open space, securing public access to the majority of the site in perpetuity, to benefit both new and existing residents. This would have delivered strong environmental and social benefits, in a more effective way than the designation as Local Green Space is capable of achieving.

9.5. The site is located within one of the identified Regeneration Corridors of the Borough, in a highly sustainable location within walking distance of a range of shops and services, including Stourbridge Town Centre. Despite the refused application P22/1050, it is maintained that the site presents an opportunity to deliver a form of residential development on part of the site, which would sit alongside open space, within a high quality green infrastructure framework. This would complement the locality, delivering much needed family housing including affordable dwellings, as well as securing public access and long-term maintenance of the site.
9.6.
As such, it is considered that it would be highly inappropriate for the emerging Plan to continue to propose to allocate the Land at Corbett Hospital in the context of a significant shortfall in housing supply and the opportunity available to provide housing in a sustainable location within the urban area. Promoting residential development on the site would accord fully with the Spatial Strategy set out in the emerging Local Plan, which establishes that the intention is to deliver growth and sustainable patterns of growth by ‘Delivering the majority of development in the existing urban area’. It should therefore be preferable to seek to accommodate some of the identified level of housing need on suitable sites such as this, rather than seeking to restrict the potential for development through the designation of a site for Local Green Space. This would ensure consistency with national policy, and contribute towards ensuring that a sound plan is achieved