Comment

Representation ID: 22157

Received: 06/10/2021

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

DUH059 - Former New Hawne Colliery
We consider that as a previously developed site, New Hawne Colliery presents a unique opportunity for new housing to be delivered as part of the regeneration of the listed buildings, and the landowners are seeking a further allocation on the adjacent former colliery land, where it would have the lowest impact in ecology and arboricultural terms.
Marlie Civils welcome the allocation of this part of the site for new housing, but would caution the council on the number of dwellings at 15, as this may not be possible for a number of reasons:

• We have yet to determine how the colliery buildings will 'convert' internally- given their unusual nature and shape, they may not lend themselves to being subdivided sufficiently to provide the sort of living space that the market would support.

• The remainder of the 'curtilage' surrounding the listed colliery buildings is, in part affected by the presence of mine shafts -where no new development can be built (with the exception of access roads). To that end, until we have been through the ground conditions report and explored how new development could work in this part of the site, this remains in doubt.

• Finally, the site also has a number of large trees around the periphery- many of the trees within the site (away from the boundary) are smaller and younger, but the trees on the boundary are generally larger more mature specimens which would be desirable to retain and conserve.

2.4. Either way, we plan to update the council on the progress on this site as plans are drawn up

We consider that there is a strong case to include some additional land at the New Hawne Colliery site as a residential allocation within the Black Country Plan. This is largely because of its highly sustainable location, it's previously developed nature and the need to cross-subsidise the costly regeneration of the important heritage assets, using new development elsewhere in appropriate less constrained locations within the site boundary.

4.2. The landowners have spent considerable sums looking at the ground conditions, ecology and trees already and this evidence will be shared with the council shortly. Following on from this, Marlie plan to prepare and submit a Vision Document which sets out how the site could deliver housing with significant benefits for the wider community in a sustainable way.

4.3. The site offers significant opportunities to add new open spaces that are properly managed and protected for future and existing residents, where access to the land is currently limited to a public rights of way along the bank of the River Stour. We urge the council to consider the site for additional housing, to deal with some of the unmet need within Dudley Borough. This would in turn, reduce the pressure on (for instance) areas of Green Belt on the periphery of the Borough.