Publication Plan April 2024

Comment

Representation ID: 5934

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

DS4 (a)
Support the level of housing provision within the policy and the overall approach taken in relation to addressing unmet housing needs.
There are elements of the policy which are 'unsound'. The policy identifies a supply that includes 10% additional homes for plan flexibility and it is expected that the delivery of any additional homes over the plan period should go towards the unmet housing needs of the GBBCHMA. The policy should explicitly express the contribution to unmet housing needs as a 'minimum'.

The draft Statement of Common Ground is to be updated and Dudley MBC will continue to engage with South Staffordshire DC under the Duty to Cooperate. It is anticipated the Black Country and other GBBCHMA authorities will seek to apportion the contribution to unmet housing needs to specific local authorities via Statements of Common Ground. Reference should be made to this process within the justification text to the policy to ensure the plan is sound.

Bullet point a) should be amended to read as follows (additional text in capitals):

4,726 homes over the period 2023-2041 to meet the district’s housing target. . . plus a MINIMUM 640-home contribution towards unmet housing needs of the Greater Birmingham and Black Country Housing Market Area. The council will seek to demonstrate a 5 year housing land supply upon adoption of the plan.

At paragraph 5.61 additional text should be included within the policy justification to reflect that the apportionment of the contribution to unmet housing needs between specific local authorities will be undertaken under the Duty to Cooperate via Statements of Common Ground.

These modifications will ensure the Local Plan is sound in terms of being ‘positively prepared’ and addressing the unmet need from neighbouring areas.

Support

Representation ID: 5935

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

DS4 (b)
Consider the policy to be sound and supports the level of employment land provision within the policy. Support the approach taken to unmet employment land needs and welcome the contribution to the unmet employment land needs of the Black Country.

Particularly support the text which identifies the contribution from the WMI to be a minimum and the acknowledgement that this contribution may increase as other authorities confirm whether they require their proportion of strategic employment land from the WMI.

An employment land shortfall of 153ha is identified within the Black Country. Offers of employment land from local authorities with functional economic links including South Staffordshire (112.2ha) which are being progressed through local plan reviews will serve to reduce this evidenced shortfall to around 11ha.

Draft Statements of Common Ground are to be updated and Dudley MBC will continue to engage with South Staffordshire DC under the Duty to Cooperate. Note that current drafts identify Stafford Borough Council do not require their WMI employment land share of 8ha and would expect these 8ha to be added to meeting the unmet employment needs of the Black Country.

Support

Representation ID: 5936

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

DS4 (c)
Considers the policy to be sound and supports the level of gypsy and traveller pitches provision within the policy, and the approach taken to identifying future site supply.

Draft Statements of Common Ground are to be updated and Dudley MBC will continue to engage with South Staffordshire DC. Discussions to date confirm Dudley MBC is unable to contribute towards the unmet needs of South Staffordshire for gypsy and traveller sites.

Support

Representation ID: 5937

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

Consider the policy to be sound and support the spatial strategy and distribution of growth outlined in the policy. Support reference to a 'minimum' of 4,726 dwellings being delivered. Dudley MBC particularly supports the identification of the district's freestanding strategic employment sites and their safeguarding for employment use.

Support

Representation ID: 5938

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

Consider the policy to be sound and supports this policy as it identifies and allocates employment sites that will assist in contributing to the unmet employment land needs of the Black Country.

Support

Representation ID: 5939

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

Consider the policy to be sound and supports this policy as it directs economic growth towards the district's strategic employment sites that will assist in contributing to the unmet employment land needs of the Black Country.

Support

Representation ID: 5940

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

Considers the policy to be sound and supports this policy as it protects the district’s strategic employment sites that will assist in contributing to the unmet employment land needs of the Black Country.

Support

Representation ID: 5941

Received: 29/05/2024

Respondent: Dudley Metropolitan Borough Council

Consider the policy to be sound and particularly supports the reference to developers and landowners being expected to work positively with neighbouring authorities as part of infrastructure provision considerations.

There are no housing or employment land allocations along the shared border with Dudley proposed in the South Staffordshire Local Plan and there have been no implications identified in respect of cross-boundary transport or other infrastructure matters to date, we support the reference to working with neighbouring authorities on all cross boundary infrastructure matters and request that this continues as the plan progresses.

South Staffordshire DC and Dudley MBC continue to work together and with other relevant stakeholders, such as Sustrans, on specific infrastructure projects where applicable including cycling/active travel links e.g. between Kinver and Dudley Borough.