Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1068

Received: 28/11/2024

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

1.Local Housing Need: The Council has not assessed whether a housing requirement greater than the LHN is justified. Large reliance on windfall sites.
2 Changes to the Standard Method and NPPF: The Council does not acknowledge the draft NPPF and the changes in national policy on plan-making.
3 GBBCHMA Unmet Needs: The DLP fails to acknowledge the unmet housing need arising from the Greater Birmingham and Black Country Housing Market Area [GBBCHMA] when seeking to export Dudley’s housing shortfall.
4 Duty to Cooperate: The Duty to Cooperate has not been fulfilled and the unmet housing need identified has been deferred rather than dealt with, contrary to NPPF
paragraph 35(c).
5 Sustainability Appraisal: The Draft Sustainability Appraisal fails to consider all of the options available to meet the LHN as well as the GBBCHMA’s unmet need, and therefore would not be justified as per NPPF paragraph 35(b).
6 The Deliverability of Brownfield Land: The proposed supply of brownfield land and windfall sites is an unrealistic and unviable strategy. In reality, the shortfall of
housing land is greater than what has been stated within the DLP.
7 Transitional Arrangements of the Draft NPPF: Based on the current arrangements, it is considered unlikely that the DLP will proceed through examination.
8 Exceptional Circumstances and Green Belt Release: The DLP does not seek to identify, allocate and release a sufficient supply of land within the Green Belt for
housing. The DLP does not recognise that exceptional circumstances for the release of land from the Green Belt exist.

Object

Representation ID: 1069

Received: 28/11/2024

Respondent: Taylor Wimpey

Agent: Lichfields

Legally compliant? No

Sound? No

Duty to co-operate? No

However, this change does not address the concerns raised by Taylor Wimpey in the regulation 18 consultation that the approach on a site-by-site basis. St Philips therefore objects to draft Policy DLP12 on the grounds of soundness as the policy should be implemented via plan-led viability testing.

Taylor Wimpey therefore objects to draft Policy DLP12 (Delivering Affordable, Wheelchair Accessible and Self-Build/Custom-Build Housing) and finds the Draft Policy to be unsound as the reliance on application-led viability testing within the draft Dudley Local Plan would
appear contrary to paragraph 58 of the NPPF.

The deliverability of Affordable, Wheelchair Accessible and Self-Build/Custom-Build Housing is critical to deliver as part of the plan strategy to meet identified needs and should be able to be achieved on sites identified for delivery through the draft Local Plan.

As such, the draft Local Plan proposing for a viability assessment to be undertaken for all applications demonstrates a clear conflict with national policy [paragraph 58] which indicates it’s at the applicant’s discretion to produce a viability assessment under particular circumstances, and not on a site-by-site basis.