Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1490

Received: 29/11/2024

Respondent: Hagley Homes

Agent: Lichfields

Draft Policy DLP31 (Nature Conservation) sets out that the Council will ensure that Sites of Local Importance for Nature Conservation are protected from development proposals which could negatively impact them. Hagley Homes notes that the site (alongside other adjacent land parcels) has been designated as a Site of Local Importance for Nature Conservation [SLINC] within the PP; this represents an expansion of the boundary of an existing SLINC designation as defined by the Dudley Borough Development Strategy (adopted 2017).
Hagley Homes supports the Councils efforts to safeguard nature conservation, however, considers that the Council should give further consideration to the site’s designation as a SLINC. In this regard, these representations provide an overview of the Councils evidence base which underpins the SLINC designation and set out the conclusions of the Preliminary Ecological Technical Note (“the appraisal”) prepared by FPCR.

Comment

Representation ID: 1494

Received: 29/11/2024

Respondent: Hagley Homes

Agent: Lichfields

The site (Land at Junction 3, M5, Halesowen) is also identified within the PP as forming part of an ‘Area of High Historic Landscape Value’ [AHHLV]. Supporting text to Draft Policy DLP60 (Areas of High Historic Landscape Value) sets out that (paragraph 14.29): “Areas of High Historic Landscape Value (AHHLV) are one of the Historic Environment Area Designations (HEADS) and define areas of landscape of acknowledged importance…Policy DLP60 aims to ensure that where new development is proposed in an AHHLV, every effort must be made to ensure it consolidates or enhances its existing positive characteristics and that views into, out of and within the AHHLV are respected.”
Hagley Homes is supportive of the Council seeking to protect important landscape areas within the Borough. However, having reviewed the Councils evidence base, Hagley Homes is concerned that the Council has not sufficiently justified the designation of the site as an AHHLV. This assertion is supported by the conclusions of a Landscape and Visual Appraisal Note, prepared by FPCR, which examines the Councils evidence base and raises concerns about the approach to identifying AHHLVs. These representations therefore review the evidence which underpins the AHHLV designation and give an overview of the conclusions reached by FPCR in respect of the site.