Publication Plan April 2024

Object

Representation ID: 6746

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes object to DS2 as written because it does not accord with national policy and is therefore not justified. The policy should accord with the wording of the PPG – “informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities…” Compensatory improvements should not necessarily have to improve access, landscape AND biodiversity.

Object

Representation ID: 6747

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Clowes object to DS4 as written because it is not justified, effective or positively prepared. The local housing need has been calculated using the standard methodology, which is a minimum. The Council should present evidence as to why its proposed housing figure does not require any additional uplift or buffering, due to economic growth for example. The policy states there is a 10% buffer, but this just comprises the contribution to the GBBCHMA, this is not considered to provide any buffer and is reliant on all of the proposed supply to be delivered.

Object

Representation ID: 6748

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

It is unclear how the 640 dwelling contribution to the GBBCHMA is considered acceptable despite an increase in the housing shortfall, or how SSDC propose to distribute these dwellings. The reduction in contribution means the Plan is not justified or effective. It is also unclear how SSDC contribution towards housing has decreased but the contribution towards employment has increased. This will lead to unsustainable patterns of travel as a greater number of people have to commute into the district for employment. It is also worth noting that SSDC were previously vocal in their objection to Plans being produced by other GBBCHMA authorities which proposed a minimal contribution.

Object

Representation ID: 6749

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

We consider a functional relationship exists in the form of the Dudley Travel to Work Area (TTWA). Clowes Development’s site at Lawnswood Road is located within the Dudley TTWA. TTWAs are based on statistical analysis rather than administrative boundaries, we consider that such measures should also be used when determining the weight given to functional relationships with other LAs.

Object

Representation ID: 6750

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? No

The housing requirement should be increased to provide a buffer to the minimum local housing need and reflect a larger contribution towards the GBBCHMA. Suitable justification for the HMA contribution figure, along with further evidence to demonstrate on-going and effective joint working with the HMA is required.

Object

Representation ID: 6751

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We object to DS5. Paragraph 5.13 states that SSDC has tested further spatial strategy options. Option I was not previously consulted on or identified as a preferred option in the 2022 Publication Plan. The PPG requires a Sustainability Appraisal and we do not consider that sufficient justification has been provided for pursuing Option I.

Object

Representation ID: 6752

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Option I appears to have been ‘created’ by the Council in order to achieve their interpretation of the amended NPPF and support the reduction in housing. SSDC have not provided justification on the reasonable alternatives assessed around the Tier 1 settlements for the HMA contribution and why the proposed capacity is limited to 640 dwellings. This approach is unjustified and unsound. Two sites have been allocated which are in the Green Belt and not in Tier 1 settlements, showing inconsistency with Option I.

The Spatial Strategy should be amended to reflect a strategy which is positively prepared and justified, providing evidence to demonstrate that the proposed strategy is truly ‘capacity-led’.

Object

Representation ID: 6753

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Land at Lawnswood Road
Greater consideration should be given to the sustainability credentials of directing development towards the edge of the Black Country. Lawnswood is classed as a Tier 5 settlement. The site adjoins the urban area of Wordsley which is linked to the wider Black Country conurbation. The adopted Dudley Borough Development Strategy states that Wordsley is a local centre (Tier 3) and the edge is approximately 1 mile from the site, with the wider Wordsley settlement bordering the site. Desktop research indicates that a number of services are located in Wordsley and it is important to consider this when looking to plan for unmet need of the wider Black Country. Plans are in the full representation (DS5) to show the facilities.

Object

Representation ID: 6754

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to HC3 as written because it is not justified. Paragraph 8.11 of the SHMA states that 14.1% of housing should be affordable rent / social rent. It is unclear why the policy wording refers to a requirement for 50% social rent and makes no reference to affordable rent. Further clarification is required on this. Policy HC3 should be amended to state ‘where viable’ in order to provide sufficient flexibility and allow tenures to be agreed between SSDC and the applicant on a site-by-site basis.

Object

Representation ID: 6755

Received: 31/05/2024

Respondent: CWC Group - Clowes Developments

Agent: Savills

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Clowes objects to HC4 as written because it is not justified, effective, or in accordance with national policy. In order to be justified in line with the PPG and NPPF, policy HC4 should be supported by a detailed analysis of how the Council considers these criteria to have been adequately addressed and evidenced. The evidence should be used as the rationale to ensure that prescribed standards in policy are not unachievable or unviable.