Object

Representation ID: 1413

Received: 13/12/2021

Respondent: CWC Group - Clowes Developments

Agent: Savills

Do not support the policy approach in Policy DS3. Paragraph 4.16 of the supporting text to policy DS3 states that the spatial strategy has been amended since the last consultation in December 2019 to reduce the amount of growth allocated to the western edge of the Black Country, reflecting the relatively limited unmet need arising from Dudley. However, having reviewed the Black Country Local Plan evidence base, it is clear that the majority of Dudley’s Green Belt that is not proposed to be released for development has constraints present on it that prevents development, such as historic landscape designations. there is shortfall between the 4,000
figure stated to be provided to the GBHMA , and the 2,958 dwellings that are planned to be located adjacent to the Black Country. The allocation of more sites adjoining the Black Country, such as Lawnswood Road (site 654) would aid this. The spatial strategy should therefore be amended to place more emphasis on the delivery of dwellings adjoining the Black Country.