Comment

Representation ID: 23580

Received: 08/10/2021

Respondent: Urban Remediation Ltd

Agent: Bright & Associates

1.2. MAPPING/STRATEGIC ALLOCATION BOUNDARY
1.2.1. There are errors on mapping boundaries regarding allocated site DUH203 on the Black Country Draft Policies Map and also the application of the Strategic Allocation boundary. These should be rectified for clarity.
1.2.2. Both the Ketley Quarry site and Ketley Farm site were remediated in 2019/2020 and have been prepared for onward housing development. There are no physical boundaries between the two areas and indeed, they are in the same ownership. In all practical sense, they can be considered as the same site.
1.2.3. The Dudley Metropolitan Borough Council (DMBC), Strategic Housing Land Availability Assessment (SHLAA) (2019-2020) update correctly identifies both the Ketley Quarry and Ketley Farm sites in their entirety. This covers a combined area of 22Ha (see Appendix 1). The Site is identified as Site 206.
1.2.4. The Black Country Draft Policies Map only shows the boundary of the Ketley Quarry Site (DUH203). To accord with the DMBC SHLAA (2019-2020), the Strategic Allocation mapping should also incorporate the Ketley Farm site. This is referenced as Site ID 247 (Ketley Farm, Dudley Road, Kingswinford) in the Black Country Call for Sites Submissions. (see Appendix 2)
1.3. SITE ALLOCATION DETAILS
1.3.1. Clarification is necessary regarding the development areas, housing numbers and deliverability with reference to the development strategy as set out in Chapter 13 Sub Areas and Site Allocations (Section A. Dudley).
1.3.2. Table 14 Dudley Housing Allocations in the Black Country Plan (BCP Policy HOU1) refers to Site reference DUH203. The Site name and address is given as Ketley Quarry/Ketley Farm, Dudley Road, Kingswinford. It has not been previously allocated and appropriate uses are noted as for housing. It identifies the indicative development capacity (net new homes) as 612 houses at 40/45 dph, The gross site area (ha) is 20.81 Ha and net site area is 13.52Ha. Anticipated delivery timescales are stated as 2024 - 2029 (50 homes), 2030 - 2035 (250 homes) and 2035 - 2039 (312 homes). It is a Strategic Allocation under Policy DSA3.
1.3.3. The Site area of Ketley Quarry and Ketley Farm is accurately measured to be 22Ha. Applying the 65% proportionality for net areas, this equates to a 14.3Ha (net) and a delivery of 644 dwellings. There are active discussions ongoing with DMBC Planning Officers as part of a pre-application process (reference PRE20/00485) with a predicted development of up to 650 dwellings. Housing availability is forecasted to commence in 2024 with an annual delivery of up to 100 dwellings per year.

1.5. POLICY DSA3 LAND AT KETLEY QUARRY KINGSWINFORD
1.5.1. This concerns an assumption of school provision within the Site and also the out of date Site descriptions which are used, given that it has now been remediated in preparation for housing development. We address each paragraph in turn. In addition, a submission is made from Highgate Land and Development concerning matters relating to affordable housing, viability assessment and education provision which have informed the development description in the Policy.
1.5.2. Paragraph A98 estimates delivery as 50 homes until 2029, 250 home between 2030 and 2035 and the remaining between 2035 and 2039. As noted above in Section 1.3, the estimated delivery will commence in 2024 with an annual release of approximately 100 dwellings.
1.5.3. School Place Requirements are set out in Paragraph A 103 and states 'Should it be determined that some form of primary school provision is required as the BCP progresses towards adoption, this may need to be accommodated on the site and land will need to be allocated to accommodate a two-form entry primary school (approximately 2.4ha)'. It is considered that the location of current school provision at both primary and secondary level is adequate. Existing facilities, necessary extensions to such facilities and the allocation can be met through required developer contributions.
1.5.4. Nature Conservation and Net Biodiversity Gain Requirements are set out in Paragraphs A105 and A106. The description of the Site is not correct. In fact, the quarry has been infilled and engineered in preparation for housing. Nor is it vegetated with ruderal species. Reference is made to a disused farmhouse for bat interest, however, this building has now been demolished under a previous planning consent.
1.5.5. The Site description is better represented by stating that both the Ketley Quarry site and adjacent Ketley Farm are bare of vegetation and is left as a levelled ground in readiness for future development.
1.5.6. Further submissions are made on the matters relating to the provision of affordable housing, the viability assessments undertaken as part of the Black Country Plan, education provision and related matters that are of concern in the application of Policy DSA3.these are contained in the copy of correspondence in Appendix 3.