Part One: Spatial Strategy and Policies (Regulation 19)

Support

Representation ID: 1310

Received: 06/12/2024

Respondent: Lichfield District Council

It is noted at paragraph 5.12 of the Dudley Local Plan that there is an employment land shortfall of 50 hectares that is to be
exported to authorities within the Functional Economic Market Area (FEMA) through the ongoing Duty to Co-operate process
and Statements of Common Ground. This employment land shortfall represents 65% of the overall employment land need
for Dudley (total 72ha). It is noted that Lichfield district is not within the same FEMA as Dudley.
It is noted that the total target figure of 72ha is increased to 98ha by adding in 26ha associated with those sites comprising
existing operational employment land which are proposed to be re-allocated for housing. Such an approach places an even
greater reliance on the unmet need for employment land to be accommodated by other authorities within the FEMA. Figure
9.2 provides details of the FEMA and it is noted that Lichfield District is assessed as having only moderate economic
transactions with Dudley. It should be noted that work on the now withdrawn Local Plan 2040 identified that there is a
limited supply of employment sites within Lichfield District and as such LDC was not able to assist in meeting unmet
employment land needs.

Support

Representation ID: 1311

Received: 06/12/2024

Respondent: Lichfield District Council

It is noted that the proposed housing requirement for the Dudley Local Plan is 11,169 homes between 2024 – 2041, as
detailed within Policy DLP1 Development Strategy and Table 5.1. This is based on the current Standard Method used to
calculate the Local Housing Need (LHN) for Dudley. Comments relating to possible future changes to LHN are set out later
within this representation.
Of this total need, it is noted that the Dudley Local Plan aims to deliver 10,470 new homes primarily through a ‘brownfield
first approach’, with 97% of the supply on brownfield land and 3% on greenfield land. This leaves a shortfall of 699 homes
that the plan states cannot be delivered within Dudley and will need to be exported through the Duty to Cooperate. It is
noted in Policies DLP49 and DLP3 that Dudley MBC (DMBC) will not be looking to review its Green Belt boundaries in order to
accommodate this shortfall.
The approach towards calculating Dudley’s own local housing requirement and the site selection process is noted, though
Lichfield District Council is concerned that DMBC’s spatial strategy does not commit to addressing the GBBCHMA shortfall
and may not have thoroughly explored all opportunities to increase housing delivery within its administrative area, including
reviewing its Green Belt to ascertain whether changes could be made to accommodate its own need. As such, LDC considers
that this unmet need could represent exceptional circumstances for reviewing DMBC’s Green Belt boundaries. Furthermore,
DMBC should identify any further potential sources of housing land supply and ensure that all development opportunities
within its administrative area are maximised prior to any shortfall being exported to other areas.

Support

Representation ID: 1313

Received: 06/12/2024

Respondent: Lichfield District Council

Policy DLP49 states that DMBC has taken the decision not to review Green Belt boundaries within the Dudley Local Plan. This
follows changes which were made to the NPPF in December 2023 which allowed authorities to determine whether they
would undertake a review of the Green Belt. It is noted that following the general election in July 2024 government have
consulted upon further changes to the NPPF which could reverse the changes made in December 2023. Should these changes
come into force this would require authorities to undertake a Green Belt review should they not be able to accommodate all
their housing within their administrative boundaries, subject to any transitional arrangements.
Whilst LDC recognises that Dudley is seeking to deliver a brownfield first strategy, it is considered that DMBC should seek to
accommodate as much housing within its own administrative boundary as possible to meet its own needs, including
considering whether Green Belt release could assist in accommodating need. Given the significant scale of the unmet needs
within the HMA and FEMA it is important that potential options for accommodating need, including within the Green Belt,
are considered and fully explored. There are limited areas beyond the Green Belt within the HMA and FEMA and should all
authorities determine not to consider their Green Belt boundaries this could significantly limit the ability of the authorities to
address these shortfalls. Indeed, the delivery of homes within DMBC’s area would ensure the homes and employment are
delivered closest to where the need arises.
DMBC will therefore need to fully justify and evidence that there are no exceptional circumstances that exist that could
justify potential Green Belt release. Given the significant level of unmet need and noting the benefits of delivering need
closes to where it arises, it is Lichfield district councils view that such circumstances exist.
It should also be noted that should the revised NPPF be published, and the transitional arrangements require, then there may
be a need for DMBC to undertake further work in relation to its green belt boundaries to fully explore all options to meet is
development needs within its own administrative area. Such work may be required to ensure that the local plan is justified.