Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1032

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

In order to meet its own needs, we consider that Dudley should seek to accommodate as much housing as possible within its own administrative boundary, including through maximising densities. Dudley should also consider whether focussed Green Belt release could assist in accommodating need.
Sandwell considers Policy DLP1to be unsound. Although Dudley have looked to utilise previously developed sites within the urban area and to increase densities, the plan doesn’t clearly set out why the Green Belt hasn’t been reviewed, especially as there are sites, previously identified as suitable, that would enable the council to meet its need in full.

Object

Representation ID: 1033

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Sandwell considers the policy to be unsound. Although Dudley have looked to utilise previously developed sites within the urban area and by increasing densities, the plan should review the Green Belt, especially as there are sites, previously identified as suitable, that would enable the council to meet its need in full.

Comment

Representation ID: 1034

Received: 28/11/2024

Respondent: Sandwell Council

Additional wording should be included at the end of paragraph 3.34 as follows:
Over the plan period, the Council will continue to regularly monitor the land supply position and keep under review any opportunities for additional supply within the borough. Mechanisms for such monitoring and review will include an annual Strategic Housing Land Availability Assessment (wherein density and other capacity assumptions can be reconsidered, and a Call for Sites undertaken); the Brownfield Register; forthcoming Design Codes, Masterplans, or any equivalent for specific areas or sites; the Housing Delivery Test Action Plan (where applicable); and the Authority Monitoring Report.

Support

Representation ID: 1035

Received: 28/11/2024

Respondent: Sandwell Council

Sandwell MBC considers the policy to be sound. We support the policy, including the justification text, para 6.24, that refers to the pooling of developer contributions, between Dudley MBC and other local authorities, where there is a cross-boundary impact.
Where housing, employment and gypsy/traveller allocations are in Sandwell’s immediate proximity, Dudley will need to take into account any cross-boundary infrastructure matters (in particular highways and education), as detailed planning applications are taken forward.

Object

Representation ID: 1036

Received: 28/11/2024

Respondent: Sandwell Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is clear that Dudley have looked to utilise previously developed sites within the urban area and increasing densities, but this plan hasn’t reviewed the Green Belt even though there are sites, previously identified as suitable, that would enable the council to meet its housing need in full.

Support

Representation ID: 1037

Received: 28/11/2024

Respondent: Sandwell Council

The Local Plan has identified 22.6ha employment land compared to a need of 72ha (98ha including replacement of employment land losses). This leaves a shortfall of 50ha (76ha including replacement of employment land losses).
Sandwell MBC considers the policy to be sound and supports the use of the jointly produced evidence base. Sandwell MBC supports ongoing joint working to address the employment land needs of the Black Country Functional Economic Market Area (FEMA). Sandwell MBC also welcomes continued joint working to produce an up-to-date shared evidence base for the employment land supply across the FEMA.

Support

Representation ID: 1038

Received: 28/11/2024

Respondent: Sandwell Council

Sandwell MBC considers these policies to be sound. We support the Local Plan policies for Strategic Employment Areas, and for Local Employment Areas, as they provide cross-boundary consistency with proposals set out in the Regulation 19 Sandwell Local Plan. They are informed by the most up to date shared evidence base, namely the Black Country Employment Area Review (BEAR, 2021). Sandwell MBC supports the use of this jointly produced evidence base.

Support

Representation ID: 1039

Received: 28/11/2024

Respondent: Sandwell Council

Sandwell MBC considers the policy to be sound. We support use of the jointly produced evidence base.
We support Dudley MBC meeting its remaining pitch/plot needs via the planning application process. Sandwell MBC is unable to contribute towards any of Dudley’s unmet needs, and has identified its own shortfall in provision for Gypsy, Traveller and Travelling Showpeople within the Regulation 19 Sandwell Local Plan.

Support

Representation ID: 1040

Received: 28/11/2024

Respondent: Sandwell Council

There are longstanding arrangements for cooperation across the four Black Country authorities in establishing transport strategy, and Sandwell Council looks forward to continuing to work with Dudley and the other Black Country councils to bring forward transport improvements to aid in delivering that strategy.
Sandwell Council recognises how important Dudley Port railway station is to Dudley MBC, and welcomes the support indicated in the Dudley Local Plan for the proposals, at this location, to develop a multi-modal interchange linking metro, rail and bus

Support

Representation ID: 1041

Received: 28/11/2024

Respondent: Sandwell Council

We welcome Dudley’s recognition that the transport impacts of development across Dudley are often cross boundary in nature; and that many of the interventions required to mitigate that impact are likewise cross boundary or sub-regional/regional in context.
There are longstanding arrangements for cooperation across the four Black Country authorities in establishing transport strategy, and Sandwell Council looks forward to continuing to work with Dudley and the other Black Country councils to bring forward transport improvements to aid in delivering that strategy.