Part Two: Centres and Site Allocations (Regulation 19)

Comment

Representation ID: 1023

Received: 27/11/2024

Respondent: Glen Dimplex Group

Agent: Glen Dimplex Group

The Publication Dudley Local Plan Part 2 sets out the policies for centres and draft site allocations. Section 6 of the Publication Local Plan Part 2 provides details of allocated housing sites.

In the Draft Local Plan (2023), the Coopers Bank site was identified as an employment site. We challenged this allocation on the basis that the evidence base used to inform the allocation was unjustified as it relied upon out- of-date information including unspecified 'market intelligence' rather than engagement with the landowner. We confirmed in our previous response that whilst the intention of the landowner is currently to stay on the northern part of the site, the southern portion is surplus to requirements and their strategy is to release this land for residential development following receipt of market advice (CBRE) and technical assessments.

We are encouraged to see that this allocation has now been changed to a proposed residential use (reference H064) within the Publication Dudley Local Plan.

The introduction of a residential use of the southern half of the site would make efficient use of brownfield land to deliver residential development to meet the housing requirement and would comprise an appropriate use adjacent to the Green Belt, Local Nature Reserve, Site of Importance for Nature Conservation, Area of High Historic Landscape Value, and Archaeological Priority Area. Additionally, it is apparent that this area is undergoing a period of transformation away from typical industrial uses to residential neighbourhoods (e.g. the former Ibstock brick works at Stallings Lane) further demonstrating the appropriateness of this site to come forward as a residential site. In addition, it is our view that the surrounding road network is more compatible with a residential use compared to an employment use. As set out in our previous response, the landowner has undertaken some due diligence into understanding the potential of the southern area for a residential use by undertaking specialist master planning, ecology, and highways work. The result of this work is that the site is capable of achieving a capacity of up to 71 dwellings (77 dwellings when counting those proposed fronting Coopers Bank Road) with a density of 40 dwellings per hectare. Highways advice concluded that there are no obvious highways issues or accident history, and it is unlikely that there would be any junction capacity issues on if a residential use was to be introduced on the land off of Coopers Bank Road. The masterplan of the site can be seen in Appendix A. In the Site Assessment Appendices (October 2024) provided as part of the evidence base to the consultation document, the Coopers Bank Road site has been subject to a detailed assessment. It identifies a number of technical aspects where assessments will be required to confirm the suitability in that regard. Such technical reports will be prepared as part of any forthcoming planning application and mitigation designed as appropriate to ensure no negative impacts in these matters will be experienced on the site. The Assessment recommends a housing density of 40-45dph which results in a capacity of 60 dwellings. In our technical assessment and indicative master planning exercise, described above, results in a housing capacity of 71 dwellings when excluding the potential dwellings fronting Coopers Bank Road. Therefore, as the assessment carried out by the landowner has been informed by specialist technical studies, we consider that the dwelling capacity of this allocation is unjustified and therefore should be increased to a minimum of 71 dwellings. This would also contribute towards Dudley achieving some of its unmet housing need (set out in policy DLP1 / Table 5.1) and strengthening the case of the policy and Plan being positively prepared and effective. The landowner intends to progress with a pre-application enquiry and intends to submit in due course with subsequent engagement with the market, thus demonstrating the deliverability of the site within the plan period.