Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1089

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

The Council will be well aware that the Government have recently concluded consultation on revisions to the Framework. The draft Framework includes transitional provisions that would apply should the Plan be submitted for examination prior to or within 1 month of publication. We understand that the Framework is due to be published before Christmas. As such, it is debatable whether the plan will be examined under the current Framework or the new Framework. As well as the transitional arrangements the draft Framework includes significant changes to Green Belt policies as well as the application of the standard method. Should the Council have to calculate its housing requirement using the updated standard method this would result in a significantly different figure to the one currently being promoted. Clearly, without second guessing what the final version of the Framework says and when it is published, should it be relevant to the preparation of the plan we would welcome the opportunity to work with the Council to resolve any issues that it may unearth and particularly if further land for housing is required as a result.

Barberry are promoting land for residential development at Swindon Road, Wall Heath, Kingswinford (referred locally as the Triangle site) and have previously submitted details of the site to the preparation of the Black Country Plan and previously representations to the Black Country Plan Preferred Options consultation that concluded in October 2021.

The Council are no longer considering the release of their Green Belt land as an option to meet its housing need, favouring exporting the problem to other yet undefined locations in the Housing Market Area (“HMA”). The current National Planning Policy Framework (‘The Framework’) states there is no requirement to review Green Belt boundaries when plans are being prepared, but it continues to allow authorities to choose to subject to demonstrating exceptional circumstances. However, it does place more of an onus on Councils to instigate this process and the weight of responsibility that comes with this should not be underestimated.

Barberry, therefore, object to the proposed strategy on the basis that the Council has not explored all the options available to meet the housing need and that it has land available in its administrative boundary to meet its identified housing need, including sites that it has previously supported as draft residential allocations in the Black Country Core Strategy review. We consider there are exceptional circumstances that warrant the Green Belt being reviewed and land released from it to help meet housing needs, which include the substantial social and economic impacts for thousands of local people and businesses.

Paragraph 60 goes on to conclude that in addition to any local housing need figure, any needs that cannot be met within neighbouring authorities should also be taken into account in establishing the amount of housing to be planned for. There is significant pressure across the HMA from constrained authorities who cannot meet their development needs within their administrative boundaries, with tens of thousands of homes and hundreds of hectares of employment land needing to be found. The number of authorities able to assist with this overspill in the HMA are limited and the evidence suggests they cannot be relied upon when the numbers they have proposed in their emerging plans to assist with addressing the overspill do not even scratch the surface. Consequently, where authorities have the land available, we consider they should be using this unless there is an overwhelming persuasive reason as to why that land should not be developed, with the argument that ‘it is Green Belt land’ not standing up to scrutiny, when it is inevitable that most of the overspill would need to be on land currently designated as Green Belt if the development needs identified are going to be met.

Further to the above, we consider that not only should Dudley be meeting its own housing need, but that it should also be assisting with meeting the overspill from other authorities, such as Birmingham, Sandwell and Wolverhampton, with whom it has a strong functional relationship and that it can provide the land in the locations to help meet the overspill from these authorities close to where the need is arising. We acknowledge that these residents might not fall in your administrative boundary, but when so many people stand to suffer from the lack of land to meet the development needs identified we would implore the Council to not allow administrative lines to stand in the way of helping these people. Accordingly, Barberry have strong reservations about whether the Council’s intended strategy is sound. The tests of soundness remain in the updated Framework as set out in paragraph 35. As it stands, Barberry consider that the Plan is not positively prepared in that does not meet the area’s objectively assessed needs and is not informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development. In light of the failure to identify where and how the Council’s unmet needs are to be met we do not consider that the Council has met the duty to cooperate.

Support

Representation ID: 1090

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

Table 4.1 sets out the Council's strategic objectives and priorities. We note Objective 1 is the conservation and enhancement of a natural and built environment including the strategic priority of addressing the climate and ecological emergency. We also welcome Strategic Priority 4 of fostering economic growth and investment and Strategic Priority 6 of creating thriving neighbourhoods by providing new and affordable homes in range of sizes, types and tenures to meet the Borough’s housing needs. Similarly, we welcome Strategic Priority 7 that seeks to deliver the resources, infrastructure and services to support growth. Barberry generally support the Objectives and Strategy Priorities of the Plan.
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Comment

Representation ID: 1092

Received: 28/11/2024

Respondent: Barberry Summerhill Limited

Agent: Harris Lamb

The Vision for Dudley sets out a number of areas that the Council wish to see achieved through the delivery of the Local Plan. These include making Dudley an attractive and desirable place to live, work and visit, having strong, inclusive resilient and thriving communities which enhance health and social wellbeing and providing a wide range of housing that will meet people's needs through their various life stages and is affordable to live in. We are generally supportive of the Vision in that it is aspirational and seeks to deliver the development needs of its residents over the Plan Period. We particularly welcome the intention to deliver a wide range of housing that will meet people's needs. Barberry supports the vision set out in the Plan.