Draft Black Country Plan

Object

Representation ID: 21829

Received: 11/10/2021

Respondent: Gutteridge & Nichols

Agent: Tyler-Parkes

[Unallocated site: Land to the rear of 24 and 30 Gorge Road]

OBJECTION to POLICY HOU1 and in particular the omission of our Client’s site for delivery of new dwellings in a highly sustainable location within the Borough.




Draft BCP Policies

Policy CSP1 (Development strategy) of the Draft Black Country Plan (BCP) indicates, inter alia, a housing growth figure of at least 47,837 net new homes within the Plan Period, with sub-paragraph 2) a) indicating that the majority of new development will be delivered within existing urban areas. Despite this, it is well known that the Dudley MBC has found it necessary to identify a number of “high profile” Green Belt sites for Housing allocation. Against this backdrop, it is respectfully suggested that every available opportunity to identify and allocate sites within the Urban areas be fully explored, to include our Clients’ site.

Policy CSP3 (Towns and Neighbourhood Areas and the green belt) indicates, inter alia, that outside the Strategic Centres and Core Regeneration Areas, 27,068 new homes will be delivered via “new homes in the urban areas through the repurposing of redundant employment sites and other surplus land” and “a supply of small-scale residential development opportunities”. It is respectfully suggested that our Clients’ site is on all-fours with these Policy requirements.

Policy HOU1 (Delivering Sustainable Housing Growth) restates the overall housing delivery figure for the Plan Period before moving on to provide a breakdown of Housing Supply at Table 3, which includes reference to a sizeable reliance upon “Windfall” sites (small sites of less than 10 dwellings or less than 0.25 hectares).

Section 13 “Sub-Areas and Site Allocations” sets out, inter alia, proposed Housing Site allocations for the Dudley MBC administrative area. Sites listed include a number of modest sized sites (with a site capacity of 10-15no. dwellings) as well as larger more strategic sites (in excess of 500no. dwellings).

For the following reasons, we consider that our Clients’ combined site should not have been omitted, either separately or combined, from the list of Housing Sites under Policy HOU1 of the draft BDP, and we OBJECT on such grounds and our Clients seek for the site to be reconsidered and included within the Housing Allocations (under Policy HOU1).



The site


Our Clients’ site is identified on the plan which accompanies this submission. The plan indicates an area identified in red, which relates to the previously developed land, with a further area shown in blue. It is acknowledged that this land in blue is located within the existing Green Belt boundary as it relates to the Turls Hill area of the Borough.

This is an established and predominantly residential area of the Borough, and the site lies in a very sustainable location with bus stops in the immediate vicinity of the site on Gorge Road; a small parade of local shops, including a Spa Supermarket, located some 220 metres (0.13 miles) to the west; and, the wider retail offer and range of facilities and services available in Sedgley some 760 metres (0.5 miles) to the west. The site is located midway between primary schools in Sedgley and Upper Ettingshall, with secondary education establishments located in Sedgley and Coseley. The site is therefore within easy access of a range of public transport, retail and community facilities.

The land to the rear of 30 Gorge Road largely consists of a lawful commercial yard extending out to the rear. The yard and associated land clearly meet the definition of previously developed land as set out within the National Planning Policy Framework (NPPF). There is an extant Outline Planning Permission for this part of the site for 8no. dwellings (Council Ref: P18/1524).

The land rear of 24 Gorge Road comprises of an area of land which is occupied by various structures associated with a horticultural business, along with an area of grazed paddock land. The site, in part, meets the definition of previously developed land as set out within the National Planning Policy Framework (NPPF).

The site is not located within an area liable to the risk of flooding as shown on the Environment Agency Flood Risk Map. None of the dwellings within the vicinity are of any special architectural significance, with the exception of the Locally Listed property that fronts the site (i.e. 30 Gorge Road itself) and the site does not lie within or near a Conservation Area. There are trees along the side boundaries of the site, as well as trees and hedgerow at the rear of the site.

Suitability for Residential Development


The overall combined red/blue line site would be capable of accommodating around 30no. new dwellings, in addition to the retention of the existing dwellings on the site. Even if the land edged in blue were not considered favourably, the red line site alone would be capable of delivering in the region of 20no. dwellings, on previously developed land within an urban area of the Borough and would therefore clearly accord with the aspirations of Policy CSP3 of the Draft BCP.

The site would make a modest, but no less valuable, contribution towards the Housing delivery targets within the overall BCP Plan Period. The site is in joint ownership of landowners who are willing to bring the site forward for residential development. There are no known legal of physical constraints which would prevent residential redevelopment of the site. Our Clients’ site is deliverable and developable in the short, medium and longer-term.

Object

Representation ID: 21830

Received: 11/10/2021

Respondent: Gutteridge & Nichols

Agent: Tyler-Parkes

Site: Land to the rear of 24 and 30 Gorge Road, Sedgley, Dudley, DY3 1LA

OBJECTION to POLICY HOU1 and in particular the omission of our Client’s site for delivery of new dwellings in a highly sustainable location within the Borough.

Policy HOU1 (Delivering Sustainable Housing Growth) restates the overall housing delivery figure for the Plan Period before moving on to provide a breakdown of Housing Supply at Table 3, which includes reference to a sizeable reliance upon “Windfall” sites (small sites of less than 10 dwellings or less than 0.25 hectares).

Section 13 “Sub-Areas and Site Allocations” sets out, inter alia, proposed Housing Site allocations for the Dudley MBC administrative area. Sites listed include a number of modest sized sites (with a site capacity of 10-15no. dwellings) as well as larger more strategic sites (in excess of 500no. dwellings).

For the following reasons, we consider that our Clients’ combined site should not have been omitted, either separately or combined, from the list of Housing Sites under Policy HOU1 of the draft BDP, and we OBJECT on such grounds and our Clients seek for the site to be reconsidered and included within the Housing Allocations (under Policy HOU1).