Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1146

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The DLP must identify more greenfield sites if it is going to deliver Dudley’s own identified housing needs, rather than continuing to rely heavily on constrained brownfield sites that have failed to deliver the homes needed to date and rather than relying heavily on neighbouring authorities to deliver its identified needs when they are similarly constrained – including by Green Belt. Given 18% of Dudley is Green Belt, this will necessitate some Green Belt release. Dudley has acknowledged that its minimum identified housing needs cannot be met if it continues to rely almost entirely on brownfield land within the urban areas. The scale of this deficiency, either on face value in the draft DLP or properly taking into account the factors discussed here which serve to exacerbate it, contributes to the exceptional circumstances required to alter the Green Belt in accordance with Framework (Paragraph 140). Previously, as part of the now defunct Black Country Plan process the Black Country Authorities, including Dudley, acknowledged that Green Belt release would be essential in order to deliver housing growth in accordance with national planning policy. That remains the case, and must be recognised by the DLP.

As discussed above, the inability of Dudley to meet its minimum housing needs is a recurrent strategic planning issue in the Borough and sub-regionally, which requires significant and bold intervention.
With brownfield opportunities becoming exhausted, and in any event failing to deliver, the DLP must identify greenfield and Green Belt release sites within Dudley to meet Dudley’s own housing needs during the DLP period, and beyond.

Persimmon Homes have promoted land at Holbeache Lane for residential development including its removal from the Green Belt to provide a deliverable site to meet housing needs. It was removed from the Green Belt and allocated for housing in the previous draft review of the Black Country Plan – its merits for removal from the Green Belt and allocation for housing remain to this day.

Object

Representation ID: 1147

Received: 29/11/2024

Respondent: Persimmon Homes

Agent: Planning Prospects Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

In conjunction with Policy DLP55, it essentially seeks to identify these areas as non-designated heritage assets. The policy is objected to. The areas of land identified in the plan are extensive and so broad as to not properly identify their significance. Further the policy affords levels of protection which are excessive, not only applying to the land identified but adjoining land and views to and from the identified AHHLV. They effectively amount to a blanket protection of all development on or anywhere near these identified areas which seems unreasonable, especially given the extent of land which they effect in the Borough.