Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1212

Received: 05/12/2024

Respondent: Walsall Council

The statement “Those development needs that cannot be accommodated within the
Dudley administrative area will be exported to sustainable locations in neighbouring local
authority areas” would not appear to be effective. Whilst the delivery of the authority’s
needs may require provision outside the area, a policy cannot make proposals for
development outside the area of the authority.

Comment

Representation ID: 1213

Received: 05/12/2024

Respondent: Walsall Council

Dudley’s Green Belt boundaries will be maintained and protected from inappropriate
development”. The word ‘boundaries’ should be omitted: it is areas within the Green Belt
that should be protected, not the boundaries.
Accessibility Standards
The means of transport to which these relate should be stated. Are they walking, cycling,
car or bus journey times?

Comment

Representation ID: 1215

Received: 05/12/2024

Respondent: Walsall Council

The policy should state that the value zones are as shown on figure 8.2 as they do not
appear to be defined anywhere else.

Comment

Representation ID: 1216

Received: 05/12/2024

Respondent: Walsall Council

Several policies refer to viability assessments. It may be helpful to provide standard
wording to describe the circumstances when these will be required and how they should
be carried out. This will provide consistency.

Comment

Representation ID: 1217

Received: 05/12/2024

Respondent: Walsall Council

Policy DLP18 would have greater clarity if the text at the end was placed after clause 1
rather than being referred to in a footnote. It should state “Further land additional to the
above figures will be required to replace any existing employment land that is lost to
alternative uses. It is anticipated that this will include 26ha which is expected to be
redeveloped for housing and other uses.”

Comment

Representation ID: 1218

Received: 05/12/2024

Respondent: Walsall Council

It is not clear what is meant by the reference in clause 4e of policy DLP18 to “opportunities
to enable those areas to be more open to, and inclusive of, the local communities which
they serve”. It is understood that the two policies are intended to be used to allocate
specific employment areas that are close to centres as locations suitable for local
community-owned enterprises that cannot be accommodated within centres, and to
improve links between those areas and the nearby centre. The supporting text gives an
example of a tap house associated with a brewery. However, it would be difficult to restrict
the use of premises to particular communities where the proposed use might otherwise be
contrary to policies relating to acceptable uses on employment land. For the policy to be
effective, it should only refer to specific industrial areas – i.e. those close to and well linked
in with existing centres – that are identified as being appropriate for these uses on the
policies map.

Comment

Representation ID: 1219

Received: 05/12/2024

Respondent: Walsall Council

Clause 1 c. of policy DLP21 refers to community, entertainment, food and drink, or leisure
and recreation uses. These are likely to be main town centre uses so should be located in
centres rather than in edge of centre or out of centre sites as this clause and paragraph
9.47 would appear to support. We understand however that the policy is only intended to
be used to allocate specific employment areas and to ensure that these uses are directed
to sequentially acceptable sites where they cannot be accommodated within the respective
centres.

Comment

Representation ID: 1237

Received: 05/12/2024

Respondent: Walsall Council

It would be helpful i the policies map included the policy numbers that relate to each of the designations, with site references for allocations.

Comment

Representation ID: 1240

Received: 05/12/2024

Respondent: Walsall Council

Concerns that the plan proposed a reduction in the supply of land for housing compared with that proposed in the BCP. The surplus of 1151 homes relatives to need over the plan period proposed in the BCP was to reduce to a shortfall of 1076 homes. This was as a result of the intention not to allocate land that is currently in Green Belt. The BCP proposals for Dudley included the provision of housing slightly in excess of local need to contribute towards the needs of Sandwell, and to a lesser extent Wolverhampton. The draft DLP however proposed to supply less than enough to meet local needs, which means that this shortfall will need to be exported to neighbouring authorities.

Comment

Representation ID: 1241

Received: 05/12/2024

Respondent: Walsall Council

The issues and options report also proposed 25ha of additional employment land compared with the 22ha proposed in the BCP. Both these figures are well below the net need of 72ha. This meant that 47ha of employment land to serve Dudley would need to be 'exported'. The supply of suitable land for employment development in Dudley is physically constrained however, so it was recommended that no concerns are raised on this topic.