Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1277

Received: 06/12/2024

Respondent: Birmingham City Council

Since the Preferred Options consultation for the DLP was done in 2023, the housing and employment land requirement figures have been updated and amended. Policy DLP1 sets out that the Strategy will deliver 10,470 net new homes and 22.6 hectares of employment land. Table 5.1 states that the housing need for Dudley, using the Government’s existing Standard Methodology, specifies that land for 11,169 homes is required by 2040/41. As with the Preferred Options document, the Policy sets out the context of how the development choices for Dudley have been made, primarily seeking to deliver development within the Borough’s Centres and Regeneration Corridors. These choices mean that land for only 10,470 homes can be identified, leaving a shortfall and unmet housing need of 699 homes (a reduction of 379 since the Preferred Options document was published).As mentioned in our response to the DLP Preferred Options, it is therefore important that Dudley continues to strive to accommodate as much housing and employment as possible to meet its own needs by making effective use of land and maximising densities and much of the DLP achieves this which is supported by the City Council. However, as previously expressed, this should also include opportunities to carry out development on the edge of the conurbation, including the release of land from the green belt as has been done in other local authorities over the last few years including Birmingham, to promote sustainable patterns of growth in line with paragraph 147 of the NPPF. This has made a significant contribution to the housing and employment land shortfalls within Birmingham through the Langley Sustainable Urban Extension and the Peddimore employment site. The latter allocation has helped in potentially enabling Birmingham to fully meet its employment land needs in the new Local Plan period up to 2042. As previously mentioned, other Councils within the Birmingham and Black Country HMA have also released Green Belt land in order to contribute to meeting their own housing and employment needs as well as contributing to the shortfall of the HMA.In view of the issues highlighted above, Birmingham City Council previously expressed disappointment that sustainable housing development sites on land currently in the Green Belt in Dudley and elsewhere in the Black Country had been removed from the potential housing supply having previously been included in the preparation and consultation of the Black Country Plan. This would have provided much needed housing growth, supported by Green Belt review evidence, to alleviate the issues highlighted above as part of sustainable patterns of growth on the edge of the conurbation in the same way that green belt land has been released in other parts of the HMA, including Birmingham.

Comment

Representation ID: 1278

Received: 06/12/2024

Respondent: Birmingham City Council

The City Council would still assert that the high levels of unmet need being experienced across the Conurbation and the wider Birmingham and Black Country HMA could be considered as exceptional enough to warrant a Green Belt boundary alteration in line with Paragraph 145 of the existing NPPF (December 2023). In addition, the ‘soundness’ requirements set out in paragraph 35 of the NPPF, which requires plans to be positively prepared in providing a strategy which seeks to meet the area’s objectively assessed needs, will also have to be considered when preparing the DLP for submission.
In July 2024, the change in Government brought about a new draft of the NPPF for consultation as well as a proposed revision to the methodology in calculating housing need for local authorities. As mentioned earlier, the proposed methodology will result in a significant reduction in the housing requirement for Birmingham but results in proposed increases to housing need in other local authority areas at a significant level including Dudley (although there is little difference in the overall need across the GBBCHMA as a whole). These changes are yet to be fully adopted following consultation but, if adopted, would add further weight to the need for Dudley to reconsider the Spatial Strategy of the DLP and reintroduce housing sites previously considered.
The transitional arrangements for the introduction of the proposed new NPPF and their effects on Local Plans have still to be confirmed, but further consideration will need to be given to these arrangements when they are expected to be published at the end of 2024. If the Plan meets the criteria for further progression set out in the transitional arrangements, then the City Council must also consider the effects of the potential change in housing needs methodology and its impact on future housing requirements and the spatial strategy for Dudley. If the DLP does proceed towards submission and potential adoption under these transitional arrangements, then the City Council would strongly promote the need for an early review of the DLP to ensure future housing needs are fully explored and appropriately planned for going forwards to ensure the needs of the GBBCHMA are met as a whole.

Comment

Representation ID: 1279

Received: 06/12/2024

Respondent: Birmingham City Council

The City Council appreciates the development pressures that Dudley, along with all local authorities across the West Midlands, is experiencing in terms of mounting housing and employment land requirements. This is further exacerbated by recent and proposed changes to the NPPF which has also had the effect of delaying or disrupting local plans and their timetables. In the DLP, Dudley has taken steps to maximise its brownfield development potential which is supported by the City Council. However, in view of the mounting shortfalls of housing land provision across the GBBCHMA, many authorities, including Birmingham, have made difficult decisions to maximise development opportunities further such as removing land from the Green Belt as a last resort when all other options have been exhausted. The City Council has previously expressed its disappointment that, having
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previously had the opportunity to alleviate some of those shortfalls by removing some sites from the green belt, Dudley have now chosen not to replicate the approach taken elsewhere and have taken these sites out of consideration. The consequence is that housing and employment opportunities will either be exported to other parts of the HMA further away from where the housing need is derived or lost altogether.
This is particularly important given the potential changes to the NPPF and the housing needs methodology which are likely place a higher burden on Dudley in meeting its future housing needs and helping to meet the housing and employment land needs across the GBBCHMA and the West Midland Functional Economic Market Area under the Duty to Cooperate. The high levels of potential unmet housing and employment land needs being experienced across the conurbation are likely to continue under any proposed housing needs methodology. This could also be considered as an exceptional circumstance to justify taking sites out of the Green Belt, as done elsewhere, in line with paragraphs 145 and 146 of the current NPPF. Reconsideration of the additional site allocations originally proposed in the BCP Preferred Options would be in line with the approach taken by other local authorities in the West Midlands in adopted or proposed local plans and would assist in removing any doubts surrounding the soundness of the DLP in being positively prepared and in accordance with the Duty to Cooperate. In addition, proposed changes to the NPPF and housing needs methodology by the new Government will necessitate careful consideration by Dudley to ensure that, firstly, transitional arrangements are being fulfilled and secondly, if so, an early review of the DLP is made to ensure that the requirements of the proposed new NPPF and housing needs methodology are fully explored and appropriately planned for by Dudley going forwards.

Comment

Representation ID: 1280

Received: 06/12/2024

Respondent: Birmingham City Council

Similarly, Policy DLP18 sets out up-to-date employment land needs for Dudley calculated to be 72 hectares (or 98 hectares if you include the need to replace sites lost to residential uses as part of the housing supply). However, this leaves a significant shortfall of nearly 50 hectares within Dudley to be met from redevelopment and intensification of existing sites and the development of sites outside of Dudley which have an evidenced functional link to the Borough through the Duty to Cooperate. This figure increases to just under 76 hectares shortfall if you include the need to replace sites lost to residential uses as part of the housing supply which are to be monitored over the Plan period. However, even taking into account these potential other employment land sources, it is anticipated that there will still be a significant employment land shortfall during the Plan period.