Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1243

Received: 05/12/2024

Respondent: Bromsgrove District Council

Bromsgrove District Council questions the timing of this consultation bearing in mind the recently published reforms to the planning system. Should these reforms remain largely unaltered following the consultation, we fail to see how the plan as it is currently drafted will be able to be found sound. The transitional arrangements would require substantial changes to the plan which would require further consultation before any submission could take place. Irrespective of the planning reforms there are still concerns with the plan as it stands

Comment

Representation ID: 1244

Received: 05/12/2024

Respondent: Bromsgrove District Council

The attempt at meeting the housing and employment needs of Dudley is acknowledged. As is the shortfall of 699 dwellings, and 50 Hectares of employment land. It is unfortunate that Dudley has decided not to meet its needs in full. We question whether the conclusion that there are no exceptional circumstances to release Green Belt sites is sound, particularly as a previous version of the Black Country Plan was directing growth to Green Belt sites in Dudley. The potential contributions from other authorities, would appear to offer some form of solution to meeting the needs in full, but clearly a position needs to be reached on how these contributions are to be distributed for this plan, and other plans in the HMA to be found sound. It is known that a Statement of Common Ground is being prepared to address apportioning this growth and it will be for the Examination in Public to determine the soundness of this approach.

Comment

Representation ID: 1245

Received: 05/12/2024

Respondent: Bromsgrove District Council

The Duty to Cooperate (DtC) has been unsuccessful in providing solutions to meeting the wider needs of the Greater Birmingham and Black Country Housing Market areas over many years. This fact and the lack of clarity in the current plan remain a concern. With the return to a more formal regional planning regime looking increasing likely, finding a solution to if/how the full housing needs of the West Midlands can be met should be progressed though this route, and not continue in the ad hoc manner as is currently taking place. A solution will need to be found by LPA's including Dudley, which allows plans to be put in place to ensure that plan led development can continue in the shorter term, but which also allows for a Spatial Development Strategy (SDS) to progress and solve those strategic issues which have failed to be solved under the (DtC).

Comment

Representation ID: 1246

Received: 05/12/2024

Respondent: Bromsgrove District Council

In order for the plan to be made sound we would suggest that the Dudley MBC withdraws the current draft plan. Following the publication of the new NPPF, and once more clarity around the role and scope of SDS's is provided, Dudley MBC can then draft and publish a plan under reg 19 which is informed by the planning framework it will be examined against.