Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1182

Received: 29/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

This objection concerns the land within the Borough on the slopes of Wychbury Hill, bounded by the Borough boundary; Hagley Road, Pedmore; Pedmore Hall Lane and Pedmore Lane. The plan will be unsound unless particular protection is provided to it as an area of Great Landscape Value and a Local Green Space.

I note (and welcome) DLP35 (Geodiversity), DLP49 (Green Belt), para 13.18 (8 Hills Regional Park), DLP52 (Geology). However, in view of the likelihood that the present government will pressurise Dudley MBC to undertake a Green Belt Review, it is desirable that this plan should provide the maximum possible protection for the best landscape assets in the Borough.

It would be good if the Plan could contain an explicit policy supporting so much of 8 Hills Regional Park as is within the Borough. I appreciate that this is currently only an emerging proposal, but it is in Dudley MBC’s power explicitly to endorse the National Trust’s proposals by means of a Policy in this Plan, which will carry much more weight than mere warm words in the supporting text.

Wychbury Hill is important:
• It is a landscape feature visible for many miles.
• It is crowned by a multivallate Iron Age hillfort, of which about one-third is within the Borough.
• The other two-thirds are part of the Hagley estate and probably within the designation of Hagley Park as Grade 1 registered parkland. The designation of the rest of the hill will serve to protect the setting of the registered park
• A geological exposure is specifically mentioned as a feature of the Black Country Geopark.
• I understand that the emerging Hagley Neighbourhood Plan intends to provide some landscape designation for the land below the summit of Wychbury Hill within Hagley, so that a similar designation of the land around Pedmore Hall within the Borough would be welcome. (I am on the committee preparing the Neighbourhood Plan, but it is only at the stage of formulating proposed policies.

Attention is drawn to the report prepared for CPRE on the Landscape of the Clent and Lickey Hills. I (as chairman of CPRE Worcestershire) ensured that the area covered included the area described in the first paragraph above. A copy of the report is attached.

Comment

Representation ID: 1354

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

There appears to be a further town centre housing opportunity site, between DLP.SH3 and Coventry Street. Some of this is needed for rear access to shops and for car parking (which is important in Stourbridge), but it should be possible to build above ground floor level. This site would include the Royal Mail yard, Eagle House Car park, and land near the end of Coventry Street that is currently used as a small municipal car park. This would provide an active frontage to St Johns Road (ring road). This is in multiple ownerships, so that Dudley MBC might have to use compulsory powers to facilitate land assembly. We suspect there may be further sites in and around Stourbridge and other town centres that could be allocated

Comment

Representation ID: 1355

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

CPRE notes that Dudley MBC is planning housing and employment land targets that are less than its objectively assessed needs. This means that the Plan will be unsound unless the council can obtain commitments from other LPAs to meet the deficit between Dudley’s needs and its land supply.

Dudley MBC may have complied with its duty to cooperate, but that does not mean that adjacent LPAs have complied with their duty to cooperate with Dudley.
The undeveloped areas of the adjacent South Stafffordshire to the west and Bromsgrove to the south are substantially all Green Belt, except land allocated for their own respective needs.
Wyre Forest to the southwest (not quite adjoining) allocated slightly more land for housing than it needed in its most recent Plan, but some of the highway connections with Dudley Borough are in some cases only via roads that are highly congested at peak times: A449, A456, A491, A451

Unmet housing need in adjoining areas. Telford and Shropshire might have surplus, but unlikely to provide homes in Dudley.

Comment

Representation ID: 1356

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Rep says DLP6.3 but comment doesn't appear to be related to policy DLP6 or paragraph 6.3.

CPRE welcomes the decision of Dudley MBC not to review the boundaries of its Green Belt, but we are concerned at the Borough’s inability to meet the whole of its development needs (see our objection to DLP1.1).

Comment

Representation ID: 1357

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

DLP7 The policy should also require the default position to be that new buildings should be connected to the highest speed broadband available locally, unless they are of a nature that makes this inappropriate or impracticable (see 6.35). As at present drafted, this is not what the policy DLP7.1 requires, contrary to the statement at 6.33. It only says that the council will support provision, not require it.

6.31 We would express surprise at the low level of full-fibre broadband: when cable TV is widely available locally via Virgin Media. Does the data only refer to BT Openreach? If so, the data used is highly defective.

Comment

Representation ID: 1358

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Policy DLP9 should encourage new healthcare facilities to be provided in or close to town and local centres, as this tends to enhance the viability of local retail centres. This encourages a person visiting their doctor or physiotherapist to pop into a nearby shop, rather than travelling to a larger retail centre further away. However, this should not prevent one healthcare facility being added adjacent to another existing one.

Object

Representation ID: 1359

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

DLP11 The use of a threshold of 10 dwellings is a distorting factor, encouraging developers to bring forward sites of 9 houses, so as not to have to comply with the density and other policies. Further detail on adverse effect of high thresholds is provided in the objection to DLP12

Object

Representation ID: 1362

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The threshold should be lower, being related to the affordable housing target, so that on all but the smallest sites the developer will be obliged to provide at least one affordable house.
Where the threshold is 10, there is a perverse incentive for developers to bring forward sites capable of accommodating 10 houses (including 3 affordable, where the target is 30%) as a site for 9 houses (with none affordable). In view of the national shortage of houses for rent, we presume that Dudley MBC wishes to maximise the delivery of affordable houses.
In medium and higher value zones, the threshold should be 3-5 according to the target: if the target is 25%, the threshold should be 4, so that on a site of 4 houses, one will be affordable. Where it is 30%, the target should be 3, again with one affordable.

Comment

Representation ID: 1364

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

There is something of a mismatch between treating the whole of Brierley Hill as a tier one centre and three towns as tier two. Brierley Hill actually consists to two separate town centres – the Strategic centre of Merry Hill and the town centre of Brierley Hill proper (the High Street, etc). There is a spatial separation between the two, including in elevation. Development between them is unlikely to change that. Merry Hill Centre should be specified as tier-1, with Brierley Hill High Street, etc as at most tier-2. This will simplify the drafting of DLP24.5, enabling protection for floors 1 and 2 at Merry Hill Centre, but only ground floor in four more traditional town centres.
The Brierley Hill Town Centre boundary includes an area west of Pedmore Road, which is wholly or mainly Saltwells Nature Reserve. This seems peculiar, even bizarre. It would be much better to use that road as the boundary. Including it in the Town Centre suggests some sinister (and unwelcome) motive for it to be developed. I

Comment

Representation ID: 1367

Received: 27/11/2024

Respondent: CPRE West Midlands Group

Agent: CPRE Worcestershire

The prohibition is likely to cause difficulties where a secondary school is within or close to a town or local centre: King Edward VI College, Stourbridge is within Stourbridge Town Centre. Old Swinford Hospital is within 400m of Stourbridge and its latest building (formerly Stourbridge College) has its main entrance on the edge of Oldswinford Local Centre. The principle of not having hot food takeaways available for use by pupils is good, but their main trade is in evenings long after pupils have gone home. The objective of the policy can therefore be secured sufficiently by imposing limitations on opening hours, rather than by a complete ban.