Object

Representation ID: 44798

Received: 11/10/2021

Respondent: Consortium of Developers

Number of people: 4

Agent: Turley Associates

Existing Allocations in Dudley
5.16 The Strategic Centre for Dudley is Brierley Hill. In 2011 the Brierley Hill Area Action Plan was examined and adopted (the AAP sets out the details of the sites to deliver the level of housing growth set by the BCCS 2011). The vision for the area in that Plan was that development would have delivered more than 3,200 new homes by 2026.

5.17 Over 26 sites are listed in the AAP as delivering residential uses in the period, the AAP was adopted in 2011 and so the evidence base for these sites is considered dated.

5.18 There is an Appendix 3 of the Dudley AAP (Implementation Framework) which shows the investment needed to regenerate the area, including identifying funding gaps and possible issues relocating existing uses. Even at the time of allocating these sites it was acknowledged that significant investment would be needed to bring them forward.

5.19 Within the AAP, at Appendix 4, set out the anticipated trajectory for delivery at the time of adoption.

See attachment for Table 5.3: Projected Net Dwelling Completions in Dudley AAP

5.20 This delivery has not materialised. The Dudley AMR (2020-2021) explains that the results from this year’s monitoring is ‘consistent with previous years’; i.e ‘limited development has yet taken place within the Brierley Hill APP Plan Area’.
5.21 The only development recorded as progressing in the last monitoring year was the redevelopment of the Canal Street Site (DOB H11) for 65 new affordable dwellings which has now completed, with 33 dwellings completed in this monitoring year and 11 residential units as part of an office conversion (see page 37 of AMR).

5.22 The evidence base suggests that 291 homes (net) have been delivered in the area since 2011. This is less than was anticipated to be delivered in the first five years following the adoption of the AAP (369 were anticipated 2011-2016).

5.23 It is understood that other sites have been granted planning permission, such as Oak Court with 78 approved residential units (ref. P18/1105/PN30 and P19/0830), however completions have not been forthcoming.

5.24 The following table sets out completions against the BCCS requirement in Brierley Hill Strategic Centre and shows that just 10.4% of the requirement has been delivered, with a 2,632 home shortfall.

See attachment for Table 5.4: Brierley Hill Net Completions

5.25 The lack of the delivery in the Strategic Location of Brierley Hill is a factor in the under delivery of Dudley as a whole against the adopted CS requirement, as is shown in Table
5.5 below.

See attachment for Table 5.5: Brierley Hill Completions against target

5.26 The Draft BCP does not provide an up to date assessment of the deliverability of Existing Allocations in Strategic Centres. They appear to have simply been re-included in the Councils’ supply without due scrutiny. The Councils also continue to include AAP sites in their assessment of five year housing land supply.

5.27 When reviewing the Council’s housing land supply and the sites from the AAP area (page 31 of the 2020 SHLAA) it is clear that there is no up to date evidence to demonstrate that these sites can be relied upon. The evidence for inclusion in the land supply table is described as ‘Yield determined through AAP evidence’. This is relying on evidence that was prepared to support a plan that was adopted over a decade ago, where there has been clear and present deliverability issues.