Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1248

Received: 29/11/2024

Respondent: Praxis Group

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DLP1 is criticized for not fully addressing the Housing Requirement and for failing to support neighbouring authorities (Wolverhampton, Sandwell, Birmingham) with unmet needs. The Duty to Cooperate is seen as insufficient, especially after the collapse of the Black Country Core Strategy.

The Housing Requirement is based on the current Standard Method, expected to increase, and if Dudley cannot avoid this, the strategy and Duty to Cooperate will need revisiting. The client, with land in South Staffordshire, offers to collaborate with Dudley and South Staffordshire to address the additional need.

The strategy's reliance on urban capacity and increased density assumptions is questioned, given stricter design requirements. To meet housing goals, design standards need adjustment or density assumptions should be reduced.

The Duty to Cooperate is deemed inadequate. The Council must restart discussions with neighbouring authorities, including South Staffordshire, and work with other Black Country authorities to address unmet housing needs.

Object

Representation ID: 1250

Received: 29/11/2024

Respondent: Praxis Group

Agent: Harris Lamb

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy DLP12, linked to DLP1, fails to address the identified affordable housing need, which requires 23.5% of housing to be affordable. Several factors contribute to this shortfall:

Sites below the threshold won't provide affordable housing, increasing the pressure on higher-threshold sites to meet the 23.5%.
Affordable housing targets for most sites are set at 10-20% based on lower and medium-value brownfield sites.
Even with all sites meeting policy, the affordable housing rate would only reach 10-20%, with some sites failing due to viability issues.
To address this unmet need, the housing requirement should be increased, or Green Belt land should be considered to deliver more affordable homes. Both options should be explored.