Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1609

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy DLP1 sets out the Council’s targets for delivering new homes (10,470) and employment land (at least 22.6 hectares) in the Borough. However, WL has significant concerns about how the Council plans to meet its housing and employment land needs, especially considering a housing shortfall of 699 dwellings. While the local housing need is calculated at 11,169 homes, the Council’s plan does not adequately address the shortfall, particularly in the context of potential Green Belt land release. WL argues that Dudley should prioritize using its own Green Belt land before seeking help from neighboring authorities, especially since other local councils (Birmingham, Sandwell, and Wolverhampton) are also facing significant housing shortfalls.

WL contends that the Council’s refusal to release Green Belt land, despite the shortfall, is short-sighted and contrary to the National Planning Policy Framework (NPPF), which allows for Green Belt reviews in exceptional circumstances. WL suggests that factors such as worsening affordability, homelessness, overcrowding, and increased economic pressures justify a review of the Green Belt. They also point out that Worcester Lane was previously identified as suitable for housing development in the Black Country Plan and should be included in the Borough Plan to help reduce the housing shortfall.

Furthermore, the plan does not address how the housing shortfalls in neighboring areas (Sandwell, Birmingham, and Wolverhampton) will be managed, totaling a combined 73,166 homes. WL believes Policy DLP1 is unsound because it fails to meet housing needs, exacerbating issues like affordability and overcrowding, and does not adequately address cross-boundary cooperation between local authorities as required by the NPPF.

Object

Representation ID: 1610

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Part 5 of the policy confirms that the Council’s Green Belt boundaries will be maintained and protected from inappropriate
development. In light of the comments we have set out in respect of policy DLP1 above WL object to this approach on the
basis that maintaining the Green Belt and seeking to direct growth to only previously developed sites will result in housing
need being unmet and a shortage of employment land being delivered through the Plan unless the Council is able to agree
with other authorities in the HMA for them to accommodate some of this unmet need. To date we cannot see that any
agreement of memorandum of understanding has been signed that demonstrates where these needs are to be met. WL
reiterate that the release of land from the Green Belt within Dudley will help ensure that Dudley is able to meet its housing
requirement of 11,169 in full within its own administrative areas without having to resort to its adjoining neighbours. The
decision to not release land from the Green Belt to meet Dudley’s needs in full will have a number of adverse consequences
for the supply of new homes and particularly the delivery of affordable homes, making the aspiration for home ownership
beyond the reach of many who live in the Borough.
WL object to Policy DLP3 and consider it unsound on the basis that it is not positively prepared nor will be it be effective and
that by not reviewing the Green Belt to meet the Council’s housing needs in full within its own administrative areas will result
in a number of problems associated with lack of adequate housing, housing affordability and knock on economic impacts
arising from a lack of working age people able to live and work in the Borough.

Object

Representation ID: 1611

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL has concerns about the Council's housing land supply outlined in Table 8.1 of the Plan. Despite a 699 dwelling shortfall, the sources of housing land supply are uncertain. For sites with planning permission, it is unclear if an implementation allowance has been applied, which typically would be around 10%. The Plan relies on redeveloping existing employment sites, but past efforts to do so under the Black Country Core Strategy were not successful. WL questions the reliability of this source and suggests a higher non-implementation allowance should be applied.

Additionally, the Plan includes a windfall allowance of 184 dwellings per year, which WL finds too high (nearly 25% of the total requirement) and lacking compelling evidence of reliability. Other sources, like occupied employment sites and office redevelopments in Brierley Hill, face uncertainties about when they will contribute to housing supply. The Plan’s overall housing supply is pegged at 10,470 homes, exactly matching the proposed requirement, but WL argues this leaves no buffer if certain sites don’t come forward as expected.

WL objects to Policy DLP10, believing it is ineffective and unlikely to meet the housing requirement due to uncertainties around land supply and delivery. A higher level of over-allocation is needed to address potential shortfalls.

Object

Representation ID: 1612

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL objects to Policy DLP11, which sets density and housing type requirements for new developments. The policy mandates that developments of 10 or more homes should meet specific density targets, ranging from 100 dwellings per hectare (dph) in strategic or town centers to 40-45 dph for moderate-density areas. However, the Dudley Housing Market Assessment (2024) indicates a significant demand for 3- and 4-bedroom homes, which are typically houses rather than apartments. This makes it difficult to achieve the required density targets while meeting the housing needs for larger family homes.

High-density developments would likely consist of smaller apartments, which do not align with the demand for larger homes. WL argues that focusing on density targets could result in a mismatch between the housing type needed and what will be delivered, particularly in town or strategic centres. Additionally, achieving high-density housing while meeting other policy objectives, like open space, design quality, and accessibility, further limits the ability to meet the housing needs for families. WL believes the policy is ineffective and that it prioritizes density over meeting the actual housing needs of the Borough.

Object

Representation ID: 1613

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL objects to Policy DLP12, which outlines thresholds for affordable housing, wheelchair accessible housing, and self-build properties.

Affordable Housing: The policy proposes 20% affordable housing on greenfield sites in medium-value zones. However, since only 3.5% of new allocations are on greenfield land, there is limited potential for affordable housing delivery. The policy also requires 10% affordable housing on previously developed sites, which may impact site viability and result in unmet housing needs.

Wheelchair Accessible Housing: WL objects to the differentiation in wheelchair accessible housing requirements based on land value zones. They argue that wheelchair users should have access to suitable housing regardless of the area’s value. Differentiating these requirements based on land value could limit the availability of accessible homes in lower-value areas, where needs are just as important.

Self-Build Housing: The policy’s 5% self-build requirement on sites over 100 dwellings is seen as excessive given the small number of individuals on the self-build register (83 people). WL suggests a 1% requirement would be more appropriate to meet the actual demand.

WL believes the policy is ineffective and inconsistent with national policy, particularly due to its reliance on land value in determining housing accessibility and affordable housing provision. They argue for allocating more sites, like Worcester Lane, that can meet policy requirements for affordable and wheelchair-accessible housing. Additionally, WL recommends reducing the self-build requirement to better match actual demand.

Object

Representation ID: 1614

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Following the enactment of the Environment Act there is now a statutory requirement to achieve 10% biodiversity net gain
through new developments. This is now a statutory requirement so there is no need for it to be included in a policy.
Notwithstanding the above, we note that policy DLP 32 sets out a requirement that all development shall deliver a minimum of
10% net gain.
In light of the statutory requirement for BNG as covered by other legislation WL do not consider the policy needs to stipulate
this. As such, we object to it not required. Rather than delete the requirement entirely could the policy be reworded to say that
delivery of BNG is required in accordance with the provisions of the Environment Act.

Object

Representation ID: 1615

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

WL objects to the Council's strategy of not meeting its housing needs within its own boundaries and instead relying on other authorities in the Housing Market Area (HMA) to accommodate the shortfall. The HMA already faces significant pressure from constrained authorities, and there is limited capacity for overspill. WL argues that Dudley should use available land, including Green Belt land, to meet its own housing needs and assist neighbouring authorities like Birmingham, Sandwell, and Wolverhampton. The failure to reach agreements on how to address unmet housing needs across the HMA suggests Dudley has not fulfilled its duty to cooperate with neighbouring councils, potentially leading to unmet housing needs and poorer housing outcomes for many residents.

Object

Representation ID: 1616

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

WL expresses concern over the Council's approach to the Local Plan, particularly the failure to address the unmet housing needs within its own boundaries and the omission of the Worcester Lane site, which could contribute significantly to housing delivery. They highlight the government's draft National Planning Policy Framework (NPPF) and the expectations for local plans, noting that the Council should ensure the plan is ready for examination and should not submit deficient plans. WL criticizes the lack of proper consideration for representations made during consultations, expressing concerns that the plan will not be thoroughly examined before submission.

WL also objects to the Council's strategy of focusing development on previously developed land and not reviewing Green Belt boundaries. They argue that this approach will lead to significant social and economic consequences for the local community and businesses, particularly given the housing shortfall. WL contends that the plan is unsound and fails to meet housing needs adequately. Their proposed solution is to allocate more land for housing, including removing land from the Green Belt where necessary.

Comment

Representation ID: 1617

Received: 12/12/2024

Respondent: Worcester Lane 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.

Object

Representation ID: 1618

Received: 12/12/2024

Respondent: Worcester Lane Limited

Agent: Harris Lamb

Legally compliant? Yes

Sound? No

Duty to co-operate? No

WL objects to the omission of Worcester Lane from the Local Plan, where it was previously considered for housing in the Black Country Plan. WL argues that the site is suitable for development, addressing housing needs in Dudley and the wider Housing Market Area (HMA). They highlight that objections to the site, such as infrastructure capacity, traffic, loss of Green Belt, and environmental concerns, can be mitigated through planning processes. WL contends that releasing Green Belt land is necessary to meet housing needs, particularly when other authorities in the HMA cannot meet their own. They argue that the site’s development would provide economic benefits and contribute to affordable housing, without significant harm to the Green Belt’s function.