Part Two: Centres and Site Allocations (Regulation 19)

Object

Representation ID: 1223

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

44. It is noted that some large employment land sites within the inner urban area are being proposed for re-development for major new housing within the council’s emerging Local Plan Review. Examples include land at Birmingham New Road, proposed for 472 new build residential dwellings. (site area 26.4
Hectares). DLP Part Two reference HO31 (site ref: CFS/SHLAA/Dev Strat) H16.1, referred to on page 212 of the DLP Part Two report (October 2024). Losing large areas of existing employment land within the inner urban area is not promoting sustainable patterns of development. The position is clear, the council’s Planning Policy Team is promoting inappropriate, damaging and unsustainable patterns of development within the local area, contrary to the “Sustainability” tests of Soundness set out under paragraph 35 (indent d) of the Revised NPPF (December 2023). The emerging Local Plan Review has also failed to consider “Reasonable alternatives” in relation to the loss of inner urban area large employment land sites. As well as failing the Sustainability test the Local Plan Review is therefore also failing Soundness tests set out under paragraph 35 (indent b) of the Revised NPPF (2023) given its continued failure to consider reasonable alternatives. The council should be releasing land from the Green Belt south of Stourbridge to help deliver thousands of new homes in order to help maintain a sufficient supply of employment land within the Dudley Borough inner urban area to help meet local community needs.

Object

Representation ID: 1227

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

. Supporting the future vitality and viability of Brierley Hill High Street is considered very important. Photographic evidence within this Local Plan Representation shows the extensive town centre decline of this once vibrant town centre location.
50. The Brierley Hill Waterfront night-time economy has declined and suffered within this once thriving and busy night-time entertainment district over the last
30 years. This area requires strong planning policy protection going forwards within Dudley Council’s emerging Local Plan Review (2024/ 2025), in order to help resurrect future night time industry uses (nightclubs, bars and restaurants) at the waterfront location. This area can play a key role in regenerating the local area in future years as the long-term economic recession gradually starts to subside, and as more supportive policies are provided for the night-time entertainment industry by central government (London) – including reversing some of the extensive damage caused to the night-time entertainment industry by Labour’s recent Autumn 2024 Budget.
51. Within Dudley Council’s emerging Local Plan Review, a very long-term planning policy view point should therefore be taken for this important and special location, the Brierley Hill Waterfront. In order to help protect this area’s important future role and function for providing an important night-time entertainment district (important for both job creation and to encourage new inward investment opportunities). As well as safeguarding this area’s role as an important future office work location. This area has huge potential to return back to a busy night-time entertainment area in future years, and as an important office work destination. The loss of extensive public carparks serving the Brierley Waterfront location to new housing development within the council’s emerging Local Plan Review, will have a damaging impact upon the economic vitality, health and viability of this location.
52. Consistent and repeated failures of centres and retail studies and employment land previous background technical evidence base studies used to support earlier Dudley Borough Local Plan Reviews, the adopted Black Country Core Strategy (2011), and the now collapsed Black Country Core Strategy (BCCS) Review (Autumn 2021). Failure to deliver meaningful changes on the ground and deliver fit-for-purpose and effective planning policy approaches for earlier Local Plan Reviews. Previous centres studies prepared by private sector planning consultants are clearly not fit-for-purpose and do now warrant the significant financial expense of commissioning these documents from so called retail and employment land specialist private sector planning consultancies. The Council now needs to use in-house expertise to complete such studies to avoid previous retail study failings, which consistently fail to deliver any meaningful and effective on-the-ground improvements within the borough’s main town centre locations centres.

Object

Representation ID: 1238

Received: 25/11/2024

Respondent: Goldfinch Town Planning Services (West Midlands)

Legally compliant? No

Sound? No

Duty to co-operate? No

. The Dudley Metropolitan Borough is a heavily urbanised area with its own set of problems. Given the long-standing severe social and economic challenges that this area continues to face (such as poor jobs growth, low levels of new inward investment, and substantial decline in the once thriving manufacturing sector industries), the Council should be prioritising high quality economic regeneration jobs growth to the borough’s existing industrial estates. To help support high quality new job creation opportunities, and positive new inward investment opportunities - which the local area so desperately needs. The proposals being taken forward within the emerging Local Plan Review fail to deliver on any of these key economic objectives, and will only serve to harm future economic recovery, encouraging new business investment growth opportunities to re-locate and focus outside of the Dudley Metropolitan Borough, in other parts of the neighbouring Black Country sub-region. The proposals being taken forward within the Local Plan Review fail to give the Dudley Metropolitan Borough local area an economic edge and advantage over the neighbouring Black Country Borough’s, and wider West Midlands Region. We have particular concerns relating to the loss of existing employment land sites within the Dudley Borough urban area as already discussed further above, as well as damaging policies being taken forward on extensive public carparks adjacent to the Brierley Hill Waterfront. The proposals being brought forward through the emerging Local Plan Review will harm the economic outlook and recovery of the local area, failing to respond effectively to guidance in paragraph 38 of the Revised NPPF (December 2023) which confirms that: “…Local planning authorities should approach decisions on proposed development in a positive and creative way. They should use the full range of planning tools available, including brownfield registers and permission in principle, and work proactively with applicants to secure developments that will improve the economic, social and environmental conditions of the area…”