Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1062

Received: 28/11/2024

Respondent: Bloor Homes

Agent: Harris Lamb

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bloor objects to Policy DLP1, arguing that it is not positively prepared, effective, or consistent with national policy. The policy’s approach to meeting housing needs in Dudley will leave a significant portion of the housing demand unmet, resulting in higher housing costs, increased overcrowding, and more people living in unsuitable housing. Beyond the social costs, Bloor emphasizes the potential economic impacts, particularly if the working-age population cannot find housing in the Borough. This could lead to outward migration, an aging population, and a reduced workforce, which would negatively affect the delivery of services.

Bloor argues that the approach in the plan is unsound and calls for Dudley to work with neighboring authorities in the Housing Market Area (HMA) to find a clear, tangible solution for addressing unmet housing needs. Without a formal, signed agreement between the authorities outlining how the unmet needs will be distributed, Bloor believes there is no realistic prospect of fully meeting housing demand in the region.
Bloor contends that Dudley should first exhaust all potential land within its boundaries, including Green Belt land, before looking to neighbouring areas. Failure to do so could result in significant adverse effects, such as local residents being unable to live in the Borough, economic issues from a shortage of working-age residents, and worsening housing conditions due to a lack of affordable housing. Bloor argues that exceptional circumstances exist for a review of the Green Belt boundaries to ensure sufficient housing delivery and avoid these negative impacts.

Object

Representation ID: 1063

Received: 28/11/2024

Respondent: Bloor Homes

Agent: Harris Lamb

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Bloor objects to Policy DLP10 on the basis that it is not effective, and as it is, the sources of supply that have been identified would not be sufficient to meet the housing requirement as proposed and that due to various reasons relating to non-implementation or delivery of certain sites/sources of supply there would be a shortfall in supply against the housing requirement. In order to address Bloor’s concerns additional land should be made available to protect against any non-implementation that may occur and to allow flexibility in meeting the needs.

Object

Representation ID: 1064

Received: 28/11/2024

Respondent: Bloor Homes

Agent: Harris Lamb

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

In light of the Council's need and the shortfall that the Council is faced with, Bloor do not consider that the Council has met its duty to cooperate. We urge the Council to enter constructive and productive discussions with the other HMA authorities, including Bromsgrove, to seek agreement on how and where this unmet housing need is going to be delivered. Meeting the housing needs of the HMA cannot be achieved on an authority by authority basis and that a joined up approach that crosses administrative boundaries will be required if there is to be any chance of meeting the HMA’s housing needs both in terms of quantum and the required mix, including affordable homes.
It is our view that the focus for addressing the shortfall in Dudley should be those authorities closest to them. Bromsgrove and South Staffordshire are the closest authorities with a meaningful ability to address the shortfall and with land available adjacent to the conurbation. The Bromsgrove plan review is still at an early stage and there is still plenty of scope to hold meaningful discussions to provide land to meet the needs arising in Sandwell.
We trust you take our comments into consideration, and we look forward to being notified of further stages of consultation on the Local Plan. If you have any questions or need to discuss, please do not hesitate to contact me.