Part One: Spatial Strategy and Policies (Regulation 19)
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Part One: Spatial Strategy and Policies (Regulation 19)
Policy DLP59 Areas of High Historic Townscape Value (AHHTV)
Representation ID: 1341
Received: 27/11/2024
Respondent: Dudley Group NHS Foundation Trust
Number of people: 2
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Similarly to Policy DLP55, these policies seek to protect non-designated heritage assets. The protection proposed would go over and above the level of protection afforded to such assets through the Framework. Furthermore, the policies as currently drafted are ambiguous as to how proposals are expected to respond to these designations, and how they will be assessed by the authority. Contribution to local character and distinctiveness are subjective matters, and it is a concern that this would be used by decision-makers to object to development proposals. In the context of unmet housing needs and significant environmental challenges and aspirations, it is considered that these policies represent an additional layer of policy that may challenge the delivery of development required to meet local needs. The Council must consider how these policies relate to national policy and guidance, and whether they are justified or necessary to remain in the emerging Plan, as these will likely be scrutinised in respect of consistency with national policy and other tests of soundness, through the plan examination process.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Policy DLP60 Areas of High Historic Landscape Value (AHHLV)
Representation ID: 1342
Received: 27/11/2024
Respondent: Dudley Group NHS Foundation Trust
Number of people: 2
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Similarly to Policy DLP55, these policies seek to protect non-designated heritage assets. The protection proposed would go over and above the level of protection afforded to such assets through the Framework. Furthermore, the policies as currently drafted are ambiguous as to how proposals are expected to respond to these designations, and how they will be assessed by the authority. Contribution to local character and distinctiveness are subjective matters, and it is a concern that this would be used by decision-makers to object to development proposals. In the context of unmet housing needs and significant environmental challenges and aspirations, it is considered that these policies represent an additional layer of policy that may challenge the delivery of development required to meet local needs. The Council must consider how these policies relate to national policy and guidance, and whether they are justified or necessary to remain in the emerging Plan, as these will likely be scrutinised in respect of consistency with national policy and other tests of soundness, through the plan examination process.
Object
Part One: Spatial Strategy and Policies (Regulation 19)
Policy DLP71 Active Travel
Representation ID: 1343
Received: 27/11/2024
Respondent: Dudley Group NHS Foundation Trust
Number of people: 2
Agent: Claremont Planning Consultancy
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
This Plan identifies a network of travel routes, focusing on existing and proposed routes for active travel, and how this connects with the Metro route. It is queried why an emerging active travel route is identified across the land at Corbett Hospital, when it the land is currently in private ownership, with no public access, particularly whilst the land remains in agricultural use. This anomaly is circled in red in the extract provided overleaf.
However, through these representations it has been demonstrated that there is the potential for the site to be opened up through development proposals, which alongside a sensitive form of residential development, there would be the potential to deliver a new public open space and connect the site into surrounding existing public footpaths connecting to existing routes to the north and south in particular.