Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1345

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Consider the policy will not deliver the necessary housing to meet the need in the area. Does not account for revised standard methodology in the NPPF. Concerned there will be a substantial amount of unmet need to be accounted for by surrounding local authorities.

Object

Representation ID: 1346

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Consider the policy will not deliver the necessary housing to meet the need in the area. Does not account for revised standard methodology in the NPPF. Concerned there will be a substantial amount of unmet need to be accounted for by surrounding local authorities.

Comment

Representation ID: 1347

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Welcome clarification that housing will be allocated on land outside of the Regeneration Corridors and Centres (this version of the plan contrasts with the original plan that proposed using "surplus land"). Unfortunate that allocations in the DLP are so reliant on redeveloping brownfield land. The viability of these projects is questioned, as the high proportion of brownfield land may struggle to deliver the necessary community benefits and affordable housing due to challenges with land values, build costs, and sales values in Dudley.

Object

Representation ID: 1348

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

To meet the growing demand for affordable housing in the Borough, more greenfield sites should be developed. Concerned that achieving the target of 32.7% affordable housing, as outlined in the Black Country SHMA (2021), will be nearly impossible under existing policies. The Dudley HMA (2024) suggests that 23.5% of new housing should be affordable, but the Viability and Delivery Study shows that the feasibility of this varies greatly depending on land value and use. A sliding scale for affordable housing, ranging from 10%-30%, is proposed, but concerned that the affordability targets, particularly on brownfield sites in medium-value areas, will be unrealistic. Vacant Building Credit can reduce the requirement to zero. Question whether the Council has adequately assessed the ability of brownfield sites to deliver affordable housing; a more accurate evidence base, including data on right-to-buy losses and stock condition, should be prepared to support the plan- need picture of net affordable housing need.

Object

Representation ID: 1349

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Do not agree with wording related to access to the countryside and open spaces for recreation. Release of Green Belt land can increase public access with new open spaces/parks and bring biodiversity net gain benefits. Agree that where Very Special Circumstances can be demonstrated planning permission should be granted, however the most appropriate way to deliver large scale new housing is through a local plan.

Object

Representation ID: 1350

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENTS ON OMISSION SITE MADE TO TABLE 6.1 OF PART TWO DUDLEY LOCAL PLAN AND EVIDENCE BASE (SHLAA, GREEN BELT REVIEW, SUSTAINABILITY APPRAISAL).

Consider omission Green Belt site (Land north of Sandyfield Road, Sedgley) should be assessed in the Strategic Housing Land Availability Assessment 2023/24. Site forms part of a wider parcel (BL10) in the Black Country Green Belt review (the part that falls within Dudley borough- remainder of site in South Staffordshire).

The Green Belt Review has not been updated or revisited since 2019 despite the housing requirement changing.

The site should be assessed as a reasonable alternative within the Sustainability Appraisal.

Vision Document for the site submitted in support of its promotion.

Object

Representation ID: 1351

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENT ON SUSTAINABILITY APPRAISAL

Do not agree with the reasoning for the selection of 'Housing Option 3' for meeting housing spatial growth. Housing need is not addressed. There is no balance as there is a particular focus on brownfield land (97% of supply). Brownfield land will not deliver the affordable housing needed- viability concerns generally. Council should consider which sites have a realistic chance of delivery. Council should not pursue a growth option where they cannot accommodate of their own growth needs without Green Belt release and rely on neighbouring authorities. The Sustainability Appraisal (SA) states the impacts of the exported unmet need cannot be fully assessed - the SA is incomplete because the strategy is flawed.

Object

Representation ID: 1352

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? No

COMMENTS ON CROSS BOUNDARY ISSUES AND DUTY TO COOPERATE (SECTION 3.30 OF DLP)

Summarises history and latest position in respect of potential housing contributions from other local authorities. Concerned that up to date Statements of Common Ground are missing from the consultation- difficult to assess what work has been undertaken to agree revised contributions and distribution of housing needs. Concerned that neighbouring authority plans have reduced housing requirements. Unclear where the unmet housing needs of the wider housing market area will be met. Query why the Council have reduced the number of homes to be accommodated within the borough and whether are complying with the Duty to Cooperate. No clear evidence that the Council have an agreed approach to the strategic delivery of housing and Green Belt review and release.

Consider there has been a failure between the neighbouring Black Country Authorities and Dudley MBC, as well as South Staffordshire, Bromsgrove and Birmingham in the Duty to Cooperate.

The Council has not met its obligations under the Duty to Cooperate or met the tests set out at Paragraph 35 of the NPPF.

Comment

Representation ID: 1353

Received: 29/11/2024

Respondent: Seven Capital

Agent: RCA Regeneration Ltd

Strategic Objective 1:
Agree with aim of Strategic Priority 1 to address the climate and ecological emergency. Partially agree with Strategic Priority 2 - question how elements related to biodiversity and ecological network enhancements will be mandated and the level of viability testing undertaken in regards to off-site improvements. Disagree with Strategic Priority 3 as if more Green Belt was released for residential development, there would be the opportunity to contribute towards the Councils' Duty to Cooperate on delivering housing.

Strategic Objective 2:
Agree with this and Strategic Priority 4.

Strategic Objective 3:
Agree with the Objective. Agree with Strategic Priority 5. Partially agree with Strategic Priority 6 in terms of meeting housing needs, but consider the Council should contribute to the unmet needs of the Greater Birmingham area. Agree with Strategic Priority 7. Agree with Strategic Priorities 8 and 9 but the Duty to Cooperate is essential in identifying and delivery cross-boundary infrastructure to facilitate unmet housing needs from neighbouring authorities.