Thank you for the opportunity to comment on the draft Sandwell Local Plan (SLP). Our response is provided in plan order by individual SLP policies. Please note this represents an officer- level response at this stage, which is subject to formal Cabinet approval in 2024.
Overall, we support continued joint working and engagement under the Duty to Cooperate as our respective Local Plans progress and welcome further discussions to address the issues identified in our response.
Policy SDS1- Development Strategy
The key elements of this policy are supported by Dudley MBC, including the principle of delivering as much new development as possible on previously developed land and sites within the urban area. Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing and employment land supply currently identified. Please note our response to Policy SHO1 in respect of the housing land supply position.
The SLP identifies that Sandwell’s unmet housing and employment land needs will need to be provided for across the Housing Market Area (HMA), Functional Economic Market Area (FEMA) and other areas with which Sandwell has a physical or functional relationship. Reference is made to the latest position in respect of the Duty to cooperate with further information contained in the supporting Draft Plan Statement of Consultation (Duty to Cooperate Statement, 2023).
This Statement (at paragraphs 31-34) identifies that there are a series of ‘offers’ from other local authorities outside of the Black Country towards the unmet housing needs of the area. Dudley MBC agrees that this largely reflects the latest position, but there are some updates to take account of. The Dudley MBC Duty to Cooperate Statement (2023) at paragraph 2.27 notes that Telford and Wrekin Council has since published its Regulation 18 Local Plan (October 2023) with a potential contribution of 1,600 homes towards the Black Country’s unmet housing needs. The Lichfield Local Plan was withdrawn from Examination in October 2023. We would also note that Cannock Chase and South Staffordshire Councils’ previously paused work on their local plans following the Government’s proposed reforms to the national planning policy framework in December 2022. We are aware that work on both plans has recently recommenced.
The Sandwell MBC Duty to Cooperate Statement (at paragraph 34) states that discussions are ongoing in relation to how these contributions are disaggregated between the four Black Country authorities, which is also reflected within the Dudley MBC Duty to Cooperate Statement (paragraph 2.26). Dudley MBC has identified a housing supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC will therefore continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
In respect of unmet employment land needs, the Sandwell MBC Duty to Cooperate Statement (paragraphs 36-41) sets out the ‘offers’ from other local authorities, which reflects the information contained within the Dudley MBC Duty to Cooperate Statement (2023). It is recognised that this reflects the position as was the case for the Black Country Local Plan draft plan consultation stage (as of 2021). The latest position, as contained within the up-to-date Black Country Economic Development Needs Assessment (EDNA, 2023) and Black Country Employment Land Supply Paper (2023) and resulting from any future updates to relevant local authority contributions, will need to be reflected at the next stage (Regulation 19) of our respective Local Plans. Dudley MBC has identified an employment land supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC supports the principle of addressing the employment land shortfalls via the Black Country FEMA and will continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
For clarity, Dudley MBC is unable to contribute towards the housing and employment land supply shortfalls of Sandwell MBC.
In respect of the other strategic matters set out within the Sandwell MBC Duty to Cooperate Statement e.g., transport, natural environment, whilst it is recognised that here will be the key prescribed bodies to engage on these matters, Dudley MBC would welcome any cross-boundary considerations related to such topics also being reflected within forthcoming Statements of Common Ground between our authorities, as necessary.
Policy SDS2- Regeneration in Sandwell
Dudley MBC supports the SLP approach of focusing new development and regeneration within the identified Regeneration Areas and West Bromwich strategic centre.
The Regeneration Area of Dudley Port and Tipton relates to the draft Dudley Local Plan Regeneration Corridor 4 (the Regeneration Area of the Wednesbury to Tipton Metro Corridor is also of relevance). Dudley MBC supports references to the new public transport hub to be developed around the interchange of the Midland Metro Extension and Dudley Port railway station. Combined with the metro extension from Dudley town centre to Dudley Port, this will provide Dudley borough residents with enhanced access to the national railway network. Housing and employment development in this area is supported but should take account of any cross-boundary infrastructure requirements arising from specific proposals.
The justification to the policy references the opportunities to build upon the existing infrastructure, making the canals and greenspace a destination, linking to wider attractions such as the Dudley Canal Trust, Black Country Museum and Dudley Zoo. Recognition of these attractions and potential opportunities to enhance linkages to them is supported.
It is noted that £20million has been awarded from the Levelling Up Fund towards the regeneration of Tipton. Whilst the principle of the regeneration and redevelopment of such areas to deliver additional housing and employment growth is supported, specific proposals for the regeneration/redevelopment of the Owen Street District Centre (also known as Tipton Town Centre) should be of an appropriate scale to that centre so as not to detract from the functions of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy SDS5 – Cultural Facilities and the Visitor Economy
Dudley MBC supports references within the justification text to assets that are also within Dudley borough, including cross-boundary sites such as Bumble Hole and Warrens Park.
Policy SNE1- Nature Conservation
Dudley MBC supports references to the protection of Fens Pool Special Area of Conservation. We would expect this to be addressed as part of the Habitats Regulation Assessment process for the SLP and individual development proposals, as necessary.
Policy SNE2- Protection and Enhancement of Wildlife Habitats
The Biodiversity Net Gain site proposals include Warren Halls Park Strategic Open Space, which represents a cross boundary opportunity with Bumble Hole Nature Reserve within Dudley borough. Bumble Hole Local Nature Reserve is identified as a potential Biodiversity Net Gain Receptor Site within the draft Dudley Local Plan.
The draft Dudley Local Plan identifies the Saltwells Local Nature Reserve as a potential Biodiversity Net Gain Receptor Site, which borders onto Mousesweet Brook Local Nature Reserve/SINC within Sandwell borough. This site is not identified within the SLP as a Biodiversity Net Gain site. There may be an opportunity for cross boundary working in relation to this area if the site was identified within the SLP. Dudley MBC will continue to work jointly with Sandwell MBC to identify any such opportunities going forward.
Dudley MBC supports the use of the Black Country Local Nature Recovery Network Strategy to maximise cross boundary benefits.
Dudley MBC welcomes the opportunity to explore and share active travel link improvements along Mousesweet Brook, Mushroom Green and Black Brook leading to Cradley Heath transport interchange (rail/bus station).
Policy SNE4- Geodiversity and the Black Country UNESCO Global Geopark
Dudley MBC supports this policy, which is consistent with draft Dudley Local Plan Policy DLP35 Geodiversity and the Black Country UNESCO Global Geopark.
Policy SHE2- Development in the Historic Environment
The policy and the supporting justification text references the Black Country Historic Landscape Characterisation Study (2019) and the supporting justification text references that Areas of High Historic Landscape (AHHLV) and Areas of High Historic Townscape value (AHHTV) were identified as part of this study. However, these areas do not then appear to be reflected within the policy itself (in terms of specific reference to them) or identified on the SLP Policies Map. There is also no reference made to the other two Historic Environment Area Designations (HEADS) identified in the Black County HLC - Designed Landscapes of High Historic Value (DLHHV) or Archaeological Priority Areas (APAs). For consistency in the implementation of the shared Black Country evidence base, and in recognition of cross boundary considerations in relation to the historic environment, Dudley MBC would welcome further references to these designations within the policy and for them to be reflected on the Policies Map. This is particularly relevant for site allocations which border/are adjacent to the Dudley borough boundary.
Policy SCC4- Flood Risk
The supporting justification text references the primary sources of fluvial flood risk within Sandwell which need to be addressed and considered. This includes the River Stour which crosses into Dudley borough. Dudley MBC supports these references.
Policy SHO1 – Delivering Sustainable Housing Growth
It is noted that 11,167 net new homes will be delivered over the plan period (up to 2041) with 97% on brownfield land and 3% on greenfield land. The SLP prioritises the development of previously developed land. The Plan identifies that there is a resulting shortfall of 18,606 homes against a housing requirement of 29,773 homes. The draft SLP states that Sandwell MBC is in discussions with neighbouring authorities to seek their agreement to accommodate some of Sandwell’s unmet needs (at paragraphs 3.12-3.19).
Dudley MBC is supportive of the Council’s approach in terms of prioritising brownfield land development in the first instance and appropriate greenfield sites within the urban area. The approach to the review of urban capacity is generally supported, and the application of assumptions related to discounting of the housing land supply is largely consistent with that applied in Dudley borough. It is noted that the Council consider there are no exceptional circumstances for the release of Green Belt land to meet identified housing needs, including the housing supply shortfall.
Dudley MBC is supportive of Sandwell MBC maximising its urban area supply to meet its own housing needs as far as possible, particularly considering the scale of the current housing supply shortfall identified (representing around two thirds of the minimum housing requirement). Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing supply identified.
It is noted that the Council has explored opportunities for additional supply from its centres (West Bromwich, Town, District and Local Centres across the borough). This yields around 219 additional dwellings. Related Policy SHO3- Housing Density, Type and Accessibility states that the highest densities of 100+ dwellings per hectare representing apartment schemes will only be acceptable where accessibility standards set out in Table 6 are met and the site is located within West Bromwich. We would welcome clarification on whether schemes located outside of West Bromwich namely at the other town centres within the borough (as identified in Table 10 of the SLP) could also achieve such higher densities given their accessible locations.
Achieving higher densities within such locations could potentially yield additional urban supply, albeit it is recognised this is unlikely to be significant in the context of the scale of the housing supply shortfall. This would however be consistent with the approach set out under the former draft Black Country Local Plan (2021) Policy HOU2 where such densities were identified as appropriate for strategic and town centres. The draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility identifies hat the strategic centre of Brierley Hill and its other town centres at Dudley, Halesowen and Stourbridge are in principle suitable for such high-density developments (subject to local character considerations for individual schemes). Please also see our response to Policy SDS1 – Development Strategy in respect of matters related to the housing supply shortfall.
It is noted there are several major housing allocations proposed along/nearby the boundary with Dudley borough including:
• SH25- Bradleys Lane/High Street, Tipton (189 dwellings)- no planning permission.
• SH1- Brown Lion Street (27 dwellings)- planning permission.
• SH7- The Boat Gauging House and adjacent land (50 dwellings)- subject of planning application.
• Several allocations around Cradley Heath including: SH16- Cradley Heath Factory Centre, Woods Lane (196 dwellings)- partly subject of planning application; SH4- Lower High Street – Station hotel and Dunns site (20 dwellings)- no planning permission; SH13- Silverthorne Lane/Forge Lane (81 dwellings)- no planning permission; SH15- Mcarthur Road Industrial Estate (13 dwellings)- no planning permission.
• SH34- Brandhall Golf Course (190 dwellings)- subject of planning application.
• Whilst located near to Rowley Regis, given the scale of the proposed allocation at SH37-Edwin Richards Quarry (526 dwellings within the plan period and 100 dwellings post plan period, partly subject of planning permission/application for 276 dwellings) we also note the relative proximity of this site to Dudley borough.
These allocations should take account of cross-boundary infrastructure considerations given the potential for the cross-boundary use of and impacts upon highways, health, and education services. Matters related to impacts upon amenity and character of the local area should also be considered on a cross boundary basis. Dudley MBC would welcome the opportunity to be consulted on any future masterplans/other planning documents that may be produced for these sites going forward (and any planning applications, as appropriate). We would also welcome the opportunity to be engaged on the Infrastructure Delivery Plan that will support the SLP as its progresses to the next Regulation 19 stage so that any cross-boundary issues can be identified and addressed.
In respect of education provision specifically, we would note that historically for cross-border flow of pupils the largest flow for Dudley MBC is with Sandwell MBC. As such Dudley MBCs education team would welcome ongoing discussions in relation to housing allocations nearby the boundary including updates on the proposed delivery timescales and Sandwell MBCs position on the education provision for such schemes. We particularly note that the SH25 allocation at Bradley’s Lane and the various allocations around Cradley Heath are located closer to primary schools within Dudley borough than those in Sandwell.
In respect of transport matters specifically, all developments exceeding 150 dwellings (as compliant with Local Transport Note LTN 1/20) at or near the Dudley MBC boundary should be considered in terms of impact on the surrounding network and subject to traffic impact assessments. All new developments should be considered in terms of opportunities to deliver active travel, Community Infrastructure Levy funds, Section 106 contributions and access to bus rail and tram transport across local authority boundaries.
Policy SHO3- Housing Density, Type and Accessibility
This policy is largely consistent with the draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility. This is supported as it provides a consistent approach to sites which are in proximity to the Dudley borough boundary.
As per our comments on Policy SHO1, we would welcome clarification as to whether town centre locations within Sandwell could accommodate higher density developments of 100+ dwellings.
Policy SHO10- Accommodation for Gypsies, Travellers and Travelling Showpeople
Dudley MBC supports the proposed protection of existing authorised pitches (16 in total) and note that 10 new pitch allocations are proposed. The proposed allocation SG1 is nearby the Dudley borough boundary at Brierley Lane for 10 pitches, which would be an extension to an existing caravan site.
Dudley MBC would welcome clarification on the size of the existing site. As set out within the SLP supporting text (paragraph 7.71) there is generally a preference for family-sized sites of 10-15 pitches. As this allocation of 10 pitches represents an extension to an existing site, we would welcome clarification of the total eventual site size including existing and proposed pitches. We would be concerned with the delivery of a site whose scale is not well related to its surrounding area. Detailed proposals for this site should take account of any cross-boundary infrastructure issues arising and matters related to impacts upon amenity and character of the local area (including within Dudley borough).
The draft SLP policies are supported by the joint evidence base produced for the Black Country; the Black Country Gypsy and Traveller Accommodation Assessment (GTAA, 2022). We welcome the use of this jointly produced evidence base. The GTTA identified a need of eight pitches up to 2031 and an additional six pitches from 2031-2041 for Sandwell. The SLP will deliver ten pitches to meet the need up to 2031 plus a buffer of two pitches (20%) - providing a five-year deliverable supply of pitches from adoption of the SLP in 2025. The approach will provide 71% of the total need for 14 pitches over the Plan period (2023-41). The SLP states that it is not possible to identify and allocate further sites to meet the remaining need for four pitches up to 2041 as no deliverable site options were put forward through the Sandwell Local Plan preparation process. Therefore, this remaining need will be met within the borough through the planning application process. This is consistent with past trends, where small windfall sites have come forward within the urban area.
The GTAA identified a need for 32 Travelling Showpeople plots for Sandwell. The SLP states it is not possible to identify and allocate sites to meet this need as no deliverable site options have been put forward through the Sandwell Local Plan preparation process. Therefore, this need will also be met within the borough, through the planning application process (and is consistent with past trends for windfall sites).
Dudley MBC is supportive of Sandwell MBC seeking to meet its outstanding needs via the planning application process. For clarity, Dudley MBC is unable to contribute towards any unmet needs of Sandwell and has identified its own shortfall in Gypsy, Traveller and Travelling Showpeople provision within the draft Dudley Local Plan.
Policy SEC1- Providing for Economic Growth and Jobs
SLP Policy SEC1- Providing for Economic Growth and Jobs, identifies that the borough will provide at least 1,206ha of employment land. This consists of 1,177ha of occupied employment which is allocated as strategic, local or other employment land and 29ha of land that is currently vacant.
The SLP notes that the latest Economic Development Needs Assessment (EDNA, produced jointly in 2023 between the Black Country local authorities) identifies an employment land requirement of 185ha for Sandwell (2020-2041). The SLP (at paragraph 2.14) states that completions for 2020-2022 and the supply of land available for employment use totals 42ha, including a vacant land supply of 29ha. There is a resulting shortfall of 143ha against Sandwell’s employment land requirements. The SLP (at the supporting text to Policy SEC1) identifies that the shortfall will be addressed through the Black Country Functional Economic Market Area (FEMA) and that unmet needs should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with Sandwell. This work is ongoing under the Duty to Cooperate.
The general approach of the SLP towards employment land provision is supported by Dudley MBC, however we would note that the EDNA published as part of the SLP consultation is dated August 2023. The most up to date version of the EDNA is October 2023, which reflects the current employment land requirements and supply position for all the four Black Country local authorities. This identifies an employment land requirement of 186ha for Sandwell, which increases to 212ha if the replacement of employment land losses is accounted for (for information, the draft Dudley Local Plan Policy DLP18- Economic growth and job creation identifies that the need for the replacement of employment land losses, equivalent to 26ha for Dudley borough, will be monitored over the plan period). We would welcome confirmation that the most current version of the EDNA (October 2023) will be used to inform the next stage of the SLP.
Dudley MBC recommends that the text at current paragraph 2.14 is replicated in the supporting justification text to Policy SEC1 to clarify that the employment land supply for Sandwell is 42ha (2020-2041). We note that EDNA and the Black Country Employment Land Supply Paper (2023) identifies an additional supply of circa 78ha arising from large and small windfall sites within the Black Country which would further reduce the employment land supply shortfall (it is noted that this figure is not disaggregated to the local authority level at this time). The borough specific contribution from the West Midlands Strategic Rail Freight Interchange (as detailed in the Stantec report of 2021)1 can also be accounted for, as per the supporting text contained within the draft Dudley Local Plan in respect of this contribution from outside the Black Country. These additional sources of supply should be recognised within the SLP supporting justification text going forward.
The latest EDNA (October 2023) and Black Country Employment Land Supply Paper (October 2023) has informed the draft Dudley Local Plan. The evidence base has been produced jointly by the Black Country local authorities, reflecting the strong FEMA that exists. This evidence base identifies individual local authority employment land requirements as part of a wider Black Country requirement. It also applies this to the employment land supply. The Employment Land Supply Paper notes the contributions that have been secured to date from other local authorities towards the Black Country employment land supply shortfall, namely from Shropshire and South Staffordshire at this time. It is envisaged that these discussions will continue as the respective local plans progress and the latest position will need to be reflected in our respective Regulation 19 local plans.
We note that there is one employment site allocation nearby the Dudley borough boundary at Coneygre Business Park for 7.22ha (reference SEC1-5). This is situated in proximity of the Strategic Employment Area (Ionic Business Park) within Dudley. The proposals for the site should take account of any cross-boundary infrastructure considerations, particularly impacts upon key infrastructure such as highways.
This site is close to the A4123/borough boundary and depending on the nature of the development, increased traffic may impact on this key route which is currently being improved to facilitate both active travel and bus route enhancements. It remains a cross boundary joint improvement initiative including input from both local authorities, Black Country Transport and Transport for the West Midlands. Continued joint working in respect of any cross-boundary implications would be welcomed, including consultations on any planning applications, as appropriate.
Policy SEC2- Strategic Employment Areas, Policy SEC3- Local Employment Areas and Policy SEC4- Other Employment Areas
Dudley MBC supports the SLP approach to Strategic Employment Areas (Policy SEC2), Local Employment Areas (Policy SEC3) and Other Employment Sites (Policy SEC4). The policy approach is broadly consistent with that set out in the draft Dudley Local Plan.
We note that the followings areas are identified as Local Employment Areas (LEA), and we support these designations as they are consistent with cross boundary/adjacent sites to the boundary of Dudley borough:
• Brymill Industrial Estate (adjacent to Budden Road, Coseley LEA in Dudley)
• The Angle Ring Company Ltd (adjacent to Budden Road, Coseley LEA in Dudley)
• Bloomfield Park (adjacent to Budden Road, Coseley and Birmingham New Road LEAs in Dudley)
• Providence Street, Cradley Heath (adjacent to Westminster Industrial Estate LEA in Dudley)
• Cakemore Industrial Estate (adjacent to Cakemore Road LEA in Dudley)
• Station Road Industrial Estate (adjacent to Nimmings Road LEA in Dudley)
It is noted that the Coneygre Industrial Estate is identified as a Local Employment Area. This lies adjacent to Ionic Business Park within Dudley borough which is identified as a Strategic Employment Area. It is noted that this reflects the findings of the Black Country Employment Area Review (BEAR, 2021).
Policy SCE1- Sandwell’s Centres, Policy SCE6- Edge of Centre and Out of Centre Development, and Town Centre Profiles
Dudley MBC supports the use of the jointly produced Black Country Centre Study update (2021) evidence base for the SLP. The draft Dudley Local Plan also utilises this evidence base.
Dudley MBC is supportive of the general approach to Centres. We are supportive of the impact test threshold of 280sqm for edge or out of centre proposals, which is consistent with draft Dudley Local Plan Policy DLP27 Edge of Centre and Out of Centre Development (we note that the contents of Table 10 of the SLP would appear to require updating to clarify this is the approach i.e., that proposals of more than 280sqm require impact tests). The implementation of the SLP policies should ensure that the scale of proposals for growth within the centres is commensurate to their scale, role, function and order in the hierarchy, taking account of nearby centres outside Sandwell borough including those in Dudley.
In relation to this, we note that for the Tier Two town centre of Blackheath there appear to be no significant proposals for growth identified. Some redevelopment site opportunities are identified, but these are not significant in scale and are for mainly residential use. For the Tier Two town centre of Cradley Heath, similarly there are no significant proposals for growth identified, with mostly residential redevelopment site opportunities identified.
As outlined in our response to Policy SDS2, the principle of the regeneration and redevelopment of Owen Street District Centre (also known as Tipton Town Centre) is supported however any specific proposals should be at a scale appropriate to the District Centre so as not to detract from the function of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy STR1- Priorities for the Development of the Transport Network
Dudley MBC supports this policy and there are several cross-boundary projects referenced, consistent with draft Dudley Local Plan Policy DLP67 The Transport Network. We are supportive of the reference to the Dudley Port Integrated Transport Hub, which will link into the Metro extension for Brierley Hill-Wednesbury and provide access to the national railway network for Dudley borough residents. The Council would welcome continued joint working on the relevant evidence base for transport matters, including transport modelling to address cross boundary matters consistently.
Policy STR2- Safeguarding the Development of the Key Route Network (KRN)
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP68 The Key Route Network. This ensures a consistent approach to cross boundary matters related to the KRN.
Policy STR4- The Efficient Movement of Freight and Logistics
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP70 The Movement of Freight. This ensures a consistent approach to cross boundary projects related to this topic, including the reopening of the Stourbridge-Walsall-Lichfield railway line (as referenced at paragraph 11.38 of the SLP). The draft Dudley Local Plan also references this project (at paragraph 16.32).
Policy STR5- Creating Coherent Networks for Cycling and Walking
The approach is broadly consistent with the draft Dudley Local Plan Policy DLP71 Active Travel. Dudley MBC supports the principle of this policy and welcomes the opportunity to continue joint working on the delivery of relevant cross boundary projects, including:
• Birmingham New Road (A4123)/Burnt Tree (A461).
• Tipton Road (A4037)/Birmingham New Road (A4123).
• Birmingham New Road (A4123)/Sedgley Road (A457).
Management of major works at the following locations will be key to sustainable travel and minimising disruption across the network:
• Birchley Island (A4123)/Churchbridge (A4034) (in close proximity to Dudley borough).
• Wolverhampton Road (A4123)/Hagley Road West (A456) (in close proximity to Dudley borough)
to rail stations such as Dudley Port station (i.e., A4123/A461 scheme), Tipton rail station, Old Hill station & Coseley station will be very helpful to both Sandwell and Dudley borough residents.
Please also see our response to Policy SNE2- Protection and Enhancement of Wildlife Habitats in respect of opportunities for active travel links.
Policy STR8- Parking Management
Dudley MBC supports this policy which is consistent with draft Dudley Local Plan Policy DLP73 Parking Management. It helps to ensure a cross boundary consistent approach to this matter, which is of relevance in relation to strategic centre and town centre parking provision. We support the use of a shared Black Country evidence base to inform this policy. The most up to date Car Parking Study has been finalised and this, or any further updates, should inform the next stage of the SLP.
Policy SWA1- Waste Infrastructure Future Requirements
This policy is broadly consistent with draft Dudley Local Plan Policy DLP75 Waste Infrastructure- Future Requirements and is therefore supported in terms of consistency in addressing cross boundary matters.
It is noted that the updated supporting evidence base for Sandwell and SLP Policy SWA1 sets out the waste infrastructure capacity gaps for the plan period. The draft Dudley Local Plan and its supporting evidence base has also identified waste infrastructure capacity gaps, particularly for those facilities which the borough is unlikely to be able to accommodate due to its urban nature e.g., landfill, anaerobic digestion and composting facilities. Dudley MBC would welcome further discussions under the Duty to Cooperate in relation to cross boundary waste matters, particularly given the existing waste movements between our local authorities. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic waste matters, including via the West Midlands Resource Technical Advisory Body (WMRTAB).
Policy SWA2- Waste Sites
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP76 Waste Sites. Dudley MBC supports the identification of strategic waste sites, applying a consistent approach in terms of how these are defined, and the use of the shared evidence base for the Black Country (Waste Study, 2020). The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-waste developments which do not prejudice existing waste-related operations.
We note that the Edwin Richards Landfill identified as a Strategic Waste Disposal Installation is also a proposed major housing allocation (allocation reference SH37) in the plan period. As this site is currently a recipient of relatively significant levels of waste from Dudley borough, we would welcome further information on the proposed timescales for its closure as part of our Duty to Cooperate discussions in respect of strategic waste matters.
Policy SWA3- Preferred Areas for New Waste Facilities
Dudley MBC supports the principle of this policy, which is consistent with draft Dudley Local Plan Policy DLP77 Preferred Areas for New Waste Facilities and is based upon a consistent evidence base for the Black Country (Waste Study, 2020). We note that the Sandwell Local Plan Policies Map identifies a ‘Preferred Area of Search’ for new waste facilities, which is a cross boundary area with Dudley borough at Bloomfield Road/Budden Road, Coseley. Whilst it is identified on the Policies Map, it is not listed in Table 13 of the supporting justification text to Policy SWA3 nor in Appendix E (where these sites are listed again). We would welcome clarification that the site is allocated and recommend it is included in the site-specific list of allocations within the SLP. Dudley MBC supports the principle of this allocation as it aligns with the draft Dudley Local Plan allocation detailed in Policy DLP77 and identified on the Policies Map. We would expect any site-specific proposals to take account of cross boundary considerations e.g., highway impacts, as part of the detailed planning application process.
We note that there are several housing allocations proposed within proximity of this preferred area (Bradleys Lane/High Street, Brown Lion Street, and The Boat Gauging House). We would expect these sites to have been assessed in terms of their potential to prejudice any existing and proposed waste operations at this location, taking account of cross boundary allocations and safeguarded sites within Dudley borough.
Policy SMI1- Minerals Safeguarding
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP80 Mineral Requirements and Policy DLP81 Mineral Safeguarding. The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-minerals developments which do not prejudice existing minerals-related operations. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic minerals matters, including via the West Midlands Aggregates Working Group and as part of the production of Local Aggregates Assessments for the West Midlands Metropolitan Area.
Appendix B- Sandwell Site Allocations (Mixed Use Allocation SM2 Lion Farm, Oldbury)
Dudley MBC would welcome further clarification in relation to Mixed Use Allocation SM2 Lion Farm, Oldbury. This represents a major allocation which is in proximity of Dudley borough and has potential cross boundary implications given its scale and current/proposed uses. The site currently provides for 6 sports pitches which have the potential for provide for cross boundary sports provision. The SLP states that appropriate uses are the retention of 6 sport pitches. The ‘Further Information’ text states that a net loss of the pitches could be avoided which is strongly caveated by the ability to relocate 6 pitches to the southern part of the borough. We would welcome clarification on whether the existing pitches are to be retained on site or relocated and if this would have any implications for cross boundary provision given the need to protect and enhance pitches across the Black Country. One of the Black Country Overarching Strategic Framework recommendations states the following for Football: Protect existing quantity of pitches, including lapsed and disused provision, until all demand is being met (unless replacement provision meets Sport England requirements and is agreed upon and provided).
The SLP states that the site will provide for 200 homes and 2.3ha of employment land. In respect of the employment land provision, we would welcome clarification if this site is proposed for B class employment use in accordance with SLP Policy SEC1. The site does not appear to be included within the B class employment land totals which are set out at Appendix C to the SLP (and already total the 29ha of vacant land referenced in SLP Policy SEC1). Dudley MBC would have concerns if this site was to be utilised for any large-scale retail development and the potential impact upon our own Tier One and Tier Two centres, plus additional impacts on highways. Any cross-boundary implications in respect of highways impacts should be fully considered. We would welcome confirmation on the specific proposals for the site.
Dudley MBC also notes the proximity of this site to the Edwin Richards Quarry site allocation (SH37). The cumulative impacts of these two allocations in terms of cross boundary infrastructure provision should be considered.

Thank you for the opportunity to comment on the draft Sandwell Local Plan (SLP). Our response is provided in plan order by individual SLP policies. Please note this represents an officer- level response at this stage, which is subject to formal Cabinet approval in 2024.
Overall, we support continued joint working and engagement under the Duty to Cooperate as our respective Local Plans progress and welcome further discussions to address the issues identified in our response.
Policy SDS1- Development Strategy
The key elements of this policy are supported by Dudley MBC, including the principle of delivering as much new development as possible on previously developed land and sites within the urban area. Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing and employment land supply currently identified. Please note our response to Policy SHO1 in respect of the housing land supply position.
The SLP identifies that Sandwell’s unmet housing and employment land needs will need to be provided for across the Housing Market Area (HMA), Functional Economic Market Area (FEMA) and other areas with which Sandwell has a physical or functional relationship. Reference is made to the latest position in respect of the Duty to cooperate with further information contained in the supporting Draft Plan Statement of Consultation (Duty to Cooperate Statement, 2023).
This Statement (at paragraphs 31-34) identifies that there are a series of ‘offers’ from other local authorities outside of the Black Country towards the unmet housing needs of the area. Dudley MBC agrees that this largely reflects the latest position, but there are some updates to take account of. The Dudley MBC Duty to Cooperate Statement (2023) at paragraph 2.27 notes that Telford and Wrekin Council has since published its Regulation 18 Local Plan (October 2023) with a potential contribution of 1,600 homes towards the Black Country’s unmet housing needs. The Lichfield Local Plan was withdrawn from Examination in October 2023. We would also note that Cannock Chase and South Staffordshire Councils’ previously paused work on their local plans following the Government’s proposed reforms to the national planning policy framework in December 2022. We are aware that work on both plans has recently recommenced.
The Sandwell MBC Duty to Cooperate Statement (at paragraph 34) states that discussions are ongoing in relation to how these contributions are disaggregated between the four Black Country authorities, which is also reflected within the Dudley MBC Duty to Cooperate Statement (paragraph 2.26). Dudley MBC has identified a housing supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC will therefore continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
In respect of unmet employment land needs, the Sandwell MBC Duty to Cooperate Statement (paragraphs 36-41) sets out the ‘offers’ from other local authorities, which reflects the information contained within the Dudley MBC Duty to Cooperate Statement (2023). It is recognised that this reflects the position as was the case for the Black Country Local Plan draft plan consultation stage (as of 2021). The latest position, as contained within the up-to-date Black Country Economic Development Needs Assessment (EDNA, 2023) and Black Country Employment Land Supply Paper (2023) and resulting from any future updates to relevant local authority contributions, will need to be reflected at the next stage (Regulation 19) of our respective Local Plans. Dudley MBC has identified an employment land supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC supports the principle of addressing the employment land shortfalls via the Black Country FEMA and will continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
For clarity, Dudley MBC is unable to contribute towards the housing and employment land supply shortfalls of Sandwell MBC.
In respect of the other strategic matters set out within the Sandwell MBC Duty to Cooperate Statement e.g., transport, natural environment, whilst it is recognised that here will be the key prescribed bodies to engage on these matters, Dudley MBC would welcome any cross-boundary considerations related to such topics also being reflected within forthcoming Statements of Common Ground between our authorities, as necessary.
Policy SDS2- Regeneration in Sandwell
Dudley MBC supports the SLP approach of focusing new development and regeneration within the identified Regeneration Areas and West Bromwich strategic centre.
The Regeneration Area of Dudley Port and Tipton relates to the draft Dudley Local Plan Regeneration Corridor 4 (the Regeneration Area of the Wednesbury to Tipton Metro Corridor is also of relevance). Dudley MBC supports references to the new public transport hub to be developed around the interchange of the Midland Metro Extension and Dudley Port railway station. Combined with the metro extension from Dudley town centre to Dudley Port, this will provide Dudley borough residents with enhanced access to the national railway network. Housing and employment development in this area is supported but should take account of any cross-boundary infrastructure requirements arising from specific proposals.
The justification to the policy references the opportunities to build upon the existing infrastructure, making the canals and greenspace a destination, linking to wider attractions such as the Dudley Canal Trust, Black Country Museum and Dudley Zoo. Recognition of these attractions and potential opportunities to enhance linkages to them is supported.
It is noted that £20million has been awarded from the Levelling Up Fund towards the regeneration of Tipton. Whilst the principle of the regeneration and redevelopment of such areas to deliver additional housing and employment growth is supported, specific proposals for the regeneration/redevelopment of the Owen Street District Centre (also known as Tipton Town Centre) should be of an appropriate scale to that centre so as not to detract from the functions of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy SDS5 – Cultural Facilities and the Visitor Economy
Dudley MBC supports references within the justification text to assets that are also within Dudley borough, including cross-boundary sites such as Bumble Hole and Warrens Park.
Policy SNE1- Nature Conservation
Dudley MBC supports references to the protection of Fens Pool Special Area of Conservation. We would expect this to be addressed as part of the Habitats Regulation Assessment process for the SLP and individual development proposals, as necessary.
Policy SNE2- Protection and Enhancement of Wildlife Habitats
The Biodiversity Net Gain site proposals include Warren Halls Park Strategic Open Space, which represents a cross boundary opportunity with Bumble Hole Nature Reserve within Dudley borough. Bumble Hole Local Nature Reserve is identified as a potential Biodiversity Net Gain Receptor Site within the draft Dudley Local Plan.
The draft Dudley Local Plan identifies the Saltwells Local Nature Reserve as a potential Biodiversity Net Gain Receptor Site, which borders onto Mousesweet Brook Local Nature Reserve/SINC within Sandwell borough. This site is not identified within the SLP as a Biodiversity Net Gain site. There may be an opportunity for cross boundary working in relation to this area if the site was identified within the SLP. Dudley MBC will continue to work jointly with Sandwell MBC to identify any such opportunities going forward.
Dudley MBC supports the use of the Black Country Local Nature Recovery Network Strategy to maximise cross boundary benefits.
Dudley MBC welcomes the opportunity to explore and share active travel link improvements along Mousesweet Brook, Mushroom Green and Black Brook leading to Cradley Heath transport interchange (rail/bus station).
Policy SNE4- Geodiversity and the Black Country UNESCO Global Geopark
Dudley MBC supports this policy, which is consistent with draft Dudley Local Plan Policy DLP35 Geodiversity and the Black Country UNESCO Global Geopark.
Policy SHE2- Development in the Historic Environment
The policy and the supporting justification text references the Black Country Historic Landscape Characterisation Study (2019) and the supporting justification text references that Areas of High Historic Landscape (AHHLV) and Areas of High Historic Townscape value (AHHTV) were identified as part of this study. However, these areas do not then appear to be reflected within the policy itself (in terms of specific reference to them) or identified on the SLP Policies Map. There is also no reference made to the other two Historic Environment Area Designations (HEADS) identified in the Black County HLC - Designed Landscapes of High Historic Value (DLHHV) or Archaeological Priority Areas (APAs). For consistency in the implementation of the shared Black Country evidence base, and in recognition of cross boundary considerations in relation to the historic environment, Dudley MBC would welcome further references to these designations within the policy and for them to be reflected on the Policies Map. This is particularly relevant for site allocations which border/are adjacent to the Dudley borough boundary.
Policy SCC4- Flood Risk
The supporting justification text references the primary sources of fluvial flood risk within Sandwell which need to be addressed and considered. This includes the River Stour which crosses into Dudley borough. Dudley MBC supports these references.
Policy SHO1 – Delivering Sustainable Housing Growth
It is noted that 11,167 net new homes will be delivered over the plan period (up to 2041) with 97% on brownfield land and 3% on greenfield land. The SLP prioritises the development of previously developed land. The Plan identifies that there is a resulting shortfall of 18,606 homes against a housing requirement of 29,773 homes. The draft SLP states that Sandwell MBC is in discussions with neighbouring authorities to seek their agreement to accommodate some of Sandwell’s unmet needs (at paragraphs 3.12-3.19).
Dudley MBC is supportive of the Council’s approach in terms of prioritising brownfield land development in the first instance and appropriate greenfield sites within the urban area. The approach to the review of urban capacity is generally supported, and the application of assumptions related to discounting of the housing land supply is largely consistent with that applied in Dudley borough. It is noted that the Council consider there are no exceptional circumstances for the release of Green Belt land to meet identified housing needs, including the housing supply shortfall.
Dudley MBC is supportive of Sandwell MBC maximising its urban area supply to meet its own housing needs as far as possible, particularly considering the scale of the current housing supply shortfall identified (representing around two thirds of the minimum housing requirement). Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing supply identified.
It is noted that the Council has explored opportunities for additional supply from its centres (West Bromwich, Town, District and Local Centres across the borough). This yields around 219 additional dwellings. Related Policy SHO3- Housing Density, Type and Accessibility states that the highest densities of 100+ dwellings per hectare representing apartment schemes will only be acceptable where accessibility standards set out in Table 6 are met and the site is located within West Bromwich. We would welcome clarification on whether schemes located outside of West Bromwich namely at the other town centres within the borough (as identified in Table 10 of the SLP) could also achieve such higher densities given their accessible locations.
Achieving higher densities within such locations could potentially yield additional urban supply, albeit it is recognised this is unlikely to be significant in the context of the scale of the housing supply shortfall. This would however be consistent with the approach set out under the former draft Black Country Local Plan (2021) Policy HOU2 where such densities were identified as appropriate for strategic and town centres. The draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility identifies hat the strategic centre of Brierley Hill and its other town centres at Dudley, Halesowen and Stourbridge are in principle suitable for such high-density developments (subject to local character considerations for individual schemes). Please also see our response to Policy SDS1 – Development Strategy in respect of matters related to the housing supply shortfall.
It is noted there are several major housing allocations proposed along/nearby the boundary with Dudley borough including:
• SH25- Bradleys Lane/High Street, Tipton (189 dwellings)- no planning permission.
• SH1- Brown Lion Street (27 dwellings)- planning permission.
• SH7- The Boat Gauging House and adjacent land (50 dwellings)- subject of planning application.
• Several allocations around Cradley Heath including: SH16- Cradley Heath Factory Centre, Woods Lane (196 dwellings)- partly subject of planning application; SH4- Lower High Street – Station hotel and Dunns site (20 dwellings)- no planning permission; SH13- Silverthorne Lane/Forge Lane (81 dwellings)- no planning permission; SH15- Mcarthur Road Industrial Estate (13 dwellings)- no planning permission.
• SH34- Brandhall Golf Course (190 dwellings)- subject of planning application.
• Whilst located near to Rowley Regis, given the scale of the proposed allocation at SH37-Edwin Richards Quarry (526 dwellings within the plan period and 100 dwellings post plan period, partly subject of planning permission/application for 276 dwellings) we also note the relative proximity of this site to Dudley borough.
These allocations should take account of cross-boundary infrastructure considerations given the potential for the cross-boundary use of and impacts upon highways, health, and education services. Matters related to impacts upon amenity and character of the local area should also be considered on a cross boundary basis. Dudley MBC would welcome the opportunity to be consulted on any future masterplans/other planning documents that may be produced for these sites going forward (and any planning applications, as appropriate). We would also welcome the opportunity to be engaged on the Infrastructure Delivery Plan that will support the SLP as its progresses to the next Regulation 19 stage so that any cross-boundary issues can be identified and addressed.
In respect of education provision specifically, we would note that historically for cross-border flow of pupils the largest flow for Dudley MBC is with Sandwell MBC. As such Dudley MBCs education team would welcome ongoing discussions in relation to housing allocations nearby the boundary including updates on the proposed delivery timescales and Sandwell MBCs position on the education provision for such schemes. We particularly note that the SH25 allocation at Bradley’s Lane and the various allocations around Cradley Heath are located closer to primary schools within Dudley borough than those in Sandwell.
In respect of transport matters specifically, all developments exceeding 150 dwellings (as compliant with Local Transport Note LTN 1/20) at or near the Dudley MBC boundary should be considered in terms of impact on the surrounding network and subject to traffic impact assessments. All new developments should be considered in terms of opportunities to deliver active travel, Community Infrastructure Levy funds, Section 106 contributions and access to bus rail and tram transport across local authority boundaries.
Policy SHO3- Housing Density, Type and Accessibility
This policy is largely consistent with the draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility. This is supported as it provides a consistent approach to sites which are in proximity to the Dudley borough boundary.
As per our comments on Policy SHO1, we would welcome clarification as to whether town centre locations within Sandwell could accommodate higher density developments of 100+ dwellings.
Policy SHO10- Accommodation for Gypsies, Travellers and Travelling Showpeople
Dudley MBC supports the proposed protection of existing authorised pitches (16 in total) and note that 10 new pitch allocations are proposed. The proposed allocation SG1 is nearby the Dudley borough boundary at Brierley Lane for 10 pitches, which would be an extension to an existing caravan site.
Dudley MBC would welcome clarification on the size of the existing site. As set out within the SLP supporting text (paragraph 7.71) there is generally a preference for family-sized sites of 10-15 pitches. As this allocation of 10 pitches represents an extension to an existing site, we would welcome clarification of the total eventual site size including existing and proposed pitches. We would be concerned with the delivery of a site whose scale is not well related to its surrounding area. Detailed proposals for this site should take account of any cross-boundary infrastructure issues arising and matters related to impacts upon amenity and character of the local area (including within Dudley borough).
The draft SLP policies are supported by the joint evidence base produced for the Black Country; the Black Country Gypsy and Traveller Accommodation Assessment (GTAA, 2022). We welcome the use of this jointly produced evidence base. The GTTA identified a need of eight pitches up to 2031 and an additional six pitches from 2031-2041 for Sandwell. The SLP will deliver ten pitches to meet the need up to 2031 plus a buffer of two pitches (20%) - providing a five-year deliverable supply of pitches from adoption of the SLP in 2025. The approach will provide 71% of the total need for 14 pitches over the Plan period (2023-41). The SLP states that it is not possible to identify and allocate further sites to meet the remaining need for four pitches up to 2041 as no deliverable site options were put forward through the Sandwell Local Plan preparation process. Therefore, this remaining need will be met within the borough through the planning application process. This is consistent with past trends, where small windfall sites have come forward within the urban area.
The GTAA identified a need for 32 Travelling Showpeople plots for Sandwell. The SLP states it is not possible to identify and allocate sites to meet this need as no deliverable site options have been put forward through the Sandwell Local Plan preparation process. Therefore, this need will also be met within the borough, through the planning application process (and is consistent with past trends for windfall sites).
Dudley MBC is supportive of Sandwell MBC seeking to meet its outstanding needs via the planning application process. For clarity, Dudley MBC is unable to contribute towards any unmet needs of Sandwell and has identified its own shortfall in Gypsy, Traveller and Travelling Showpeople provision within the draft Dudley Local Plan.
Policy SEC1- Providing for Economic Growth and Jobs
SLP Policy SEC1- Providing for Economic Growth and Jobs, identifies that the borough will provide at least 1,206ha of employment land. This consists of 1,177ha of occupied employment which is allocated as strategic, local or other employment land and 29ha of land that is currently vacant.
The SLP notes that the latest Economic Development Needs Assessment (EDNA, produced jointly in 2023 between the Black Country local authorities) identifies an employment land requirement of 185ha for Sandwell (2020-2041). The SLP (at paragraph 2.14) states that completions for 2020-2022 and the supply of land available for employment use totals 42ha, including a vacant land supply of 29ha. There is a resulting shortfall of 143ha against Sandwell’s employment land requirements. The SLP (at the supporting text to Policy SEC1) identifies that the shortfall will be addressed through the Black Country Functional Economic Market Area (FEMA) and that unmet needs should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with Sandwell. This work is ongoing under the Duty to Cooperate.
The general approach of the SLP towards employment land provision is supported by Dudley MBC, however we would note that the EDNA published as part of the SLP consultation is dated August 2023. The most up to date version of the EDNA is October 2023, which reflects the current employment land requirements and supply position for all the four Black Country local authorities. This identifies an employment land requirement of 186ha for Sandwell, which increases to 212ha if the replacement of employment land losses is accounted for (for information, the draft Dudley Local Plan Policy DLP18- Economic growth and job creation identifies that the need for the replacement of employment land losses, equivalent to 26ha for Dudley borough, will be monitored over the plan period). We would welcome confirmation that the most current version of the EDNA (October 2023) will be used to inform the next stage of the SLP.
Dudley MBC recommends that the text at current paragraph 2.14 is replicated in the supporting justification text to Policy SEC1 to clarify that the employment land supply for Sandwell is 42ha (2020-2041). We note that EDNA and the Black Country Employment Land Supply Paper (2023) identifies an additional supply of circa 78ha arising from large and small windfall sites within the Black Country which would further reduce the employment land supply shortfall (it is noted that this figure is not disaggregated to the local authority level at this time). The borough specific contribution from the West Midlands Strategic Rail Freight Interchange (as detailed in the Stantec report of 2021)1 can also be accounted for, as per the supporting text contained within the draft Dudley Local Plan in respect of this contribution from outside the Black Country. These additional sources of supply should be recognised within the SLP supporting justification text going forward.
The latest EDNA (October 2023) and Black Country Employment Land Supply Paper (October 2023) has informed the draft Dudley Local Plan. The evidence base has been produced jointly by the Black Country local authorities, reflecting the strong FEMA that exists. This evidence base identifies individual local authority employment land requirements as part of a wider Black Country requirement. It also applies this to the employment land supply. The Employment Land Supply Paper notes the contributions that have been secured to date from other local authorities towards the Black Country employment land supply shortfall, namely from Shropshire and South Staffordshire at this time. It is envisaged that these discussions will continue as the respective local plans progress and the latest position will need to be reflected in our respective Regulation 19 local plans.
We note that there is one employment site allocation nearby the Dudley borough boundary at Coneygre Business Park for 7.22ha (reference SEC1-5). This is situated in proximity of the Strategic Employment Area (Ionic Business Park) within Dudley. The proposals for the site should take account of any cross-boundary infrastructure considerations, particularly impacts upon key infrastructure such as highways.
This site is close to the A4123/borough boundary and depending on the nature of the development, increased traffic may impact on this key route which is currently being improved to facilitate both active travel and bus route enhancements. It remains a cross boundary joint improvement initiative including input from both local authorities, Black Country Transport and Transport for the West Midlands. Continued joint working in respect of any cross-boundary implications would be welcomed, including consultations on any planning applications, as appropriate.
Policy SEC2- Strategic Employment Areas, Policy SEC3- Local Employment Areas and Policy SEC4- Other Employment Areas
Dudley MBC supports the SLP approach to Strategic Employment Areas (Policy SEC2), Local Employment Areas (Policy SEC3) and Other Employment Sites (Policy SEC4). The policy approach is broadly consistent with that set out in the draft Dudley Local Plan.
We note that the followings areas are identified as Local Employment Areas (LEA), and we support these designations as they are consistent with cross boundary/adjacent sites to the boundary of Dudley borough:
• Brymill Industrial Estate (adjacent to Budden Road, Coseley LEA in Dudley)
• The Angle Ring Company Ltd (adjacent to Budden Road, Coseley LEA in Dudley)
• Bloomfield Park (adjacent to Budden Road, Coseley and Birmingham New Road LEAs in Dudley)
• Providence Street, Cradley Heath (adjacent to Westminster Industrial Estate LEA in Dudley)
• Cakemore Industrial Estate (adjacent to Cakemore Road LEA in Dudley)
• Station Road Industrial Estate (adjacent to Nimmings Road LEA in Dudley)
It is noted that the Coneygre Industrial Estate is identified as a Local Employment Area. This lies adjacent to Ionic Business Park within Dudley borough which is identified as a Strategic Employment Area. It is noted that this reflects the findings of the Black Country Employment Area Review (BEAR, 2021).
Policy SCE1- Sandwell’s Centres, Policy SCE6- Edge of Centre and Out of Centre Development, and Town Centre Profiles
Dudley MBC supports the use of the jointly produced Black Country Centre Study update (2021) evidence base for the SLP. The draft Dudley Local Plan also utilises this evidence base.
Dudley MBC is supportive of the general approach to Centres. We are supportive of the impact test threshold of 280sqm for edge or out of centre proposals, which is consistent with draft Dudley Local Plan Policy DLP27 Edge of Centre and Out of Centre Development (we note that the contents of Table 10 of the SLP would appear to require updating to clarify this is the approach i.e., that proposals of more than 280sqm require impact tests). The implementation of the SLP policies should ensure that the scale of proposals for growth within the centres is commensurate to their scale, role, function and order in the hierarchy, taking account of nearby centres outside Sandwell borough including those in Dudley.
In relation to this, we note that for the Tier Two town centre of Blackheath there appear to be no significant proposals for growth identified. Some redevelopment site opportunities are identified, but these are not significant in scale and are for mainly residential use. For the Tier Two town centre of Cradley Heath, similarly there are no significant proposals for growth identified, with mostly residential redevelopment site opportunities identified.
As outlined in our response to Policy SDS2, the principle of the regeneration and redevelopment of Owen Street District Centre (also known as Tipton Town Centre) is supported however any specific proposals should be at a scale appropriate to the District Centre so as not to detract from the function of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy STR1- Priorities for the Development of the Transport Network
Dudley MBC supports this policy and there are several cross-boundary projects referenced, consistent with draft Dudley Local Plan Policy DLP67 The Transport Network. We are supportive of the reference to the Dudley Port Integrated Transport Hub, which will link into the Metro extension for Brierley Hill-Wednesbury and provide access to the national railway network for Dudley borough residents. The Council would welcome continued joint working on the relevant evidence base for transport matters, including transport modelling to address cross boundary matters consistently.
Policy STR2- Safeguarding the Development of the Key Route Network (KRN)
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP68 The Key Route Network. This ensures a consistent approach to cross boundary matters related to the KRN.
Policy STR4- The Efficient Movement of Freight and Logistics
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP70 The Movement of Freight. This ensures a consistent approach to cross boundary projects related to this topic, including the reopening of the Stourbridge-Walsall-Lichfield railway line (as referenced at paragraph 11.38 of the SLP). The draft Dudley Local Plan also references this project (at paragraph 16.32).
Policy STR5- Creating Coherent Networks for Cycling and Walking
The approach is broadly consistent with the draft Dudley Local Plan Policy DLP71 Active Travel. Dudley MBC supports the principle of this policy and welcomes the opportunity to continue joint working on the delivery of relevant cross boundary projects, including:
• Birmingham New Road (A4123)/Burnt Tree (A461).
• Tipton Road (A4037)/Birmingham New Road (A4123).
• Birmingham New Road (A4123)/Sedgley Road (A457).
Management of major works at the following locations will be key to sustainable travel and minimising disruption across the network:
• Birchley Island (A4123)/Churchbridge (A4034) (in close proximity to Dudley borough).
• Wolverhampton Road (A4123)/Hagley Road West (A456) (in close proximity to Dudley borough)
to rail stations such as Dudley Port station (i.e., A4123/A461 scheme), Tipton rail station, Old Hill station & Coseley station will be very helpful to both Sandwell and Dudley borough residents.
Please also see our response to Policy SNE2- Protection and Enhancement of Wildlife Habitats in respect of opportunities for active travel links.
Policy STR8- Parking Management
Dudley MBC supports this policy which is consistent with draft Dudley Local Plan Policy DLP73 Parking Management. It helps to ensure a cross boundary consistent approach to this matter, which is of relevance in relation to strategic centre and town centre parking provision. We support the use of a shared Black Country evidence base to inform this policy. The most up to date Car Parking Study has been finalised and this, or any further updates, should inform the next stage of the SLP.
Policy SWA1- Waste Infrastructure Future Requirements
This policy is broadly consistent with draft Dudley Local Plan Policy DLP75 Waste Infrastructure- Future Requirements and is therefore supported in terms of consistency in addressing cross boundary matters.
It is noted that the updated supporting evidence base for Sandwell and SLP Policy SWA1 sets out the waste infrastructure capacity gaps for the plan period. The draft Dudley Local Plan and its supporting evidence base has also identified waste infrastructure capacity gaps, particularly for those facilities which the borough is unlikely to be able to accommodate due to its urban nature e.g., landfill, anaerobic digestion and composting facilities. Dudley MBC would welcome further discussions under the Duty to Cooperate in relation to cross boundary waste matters, particularly given the existing waste movements between our local authorities. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic waste matters, including via the West Midlands Resource Technical Advisory Body (WMRTAB).
Policy SWA2- Waste Sites
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP76 Waste Sites. Dudley MBC supports the identification of strategic waste sites, applying a consistent approach in terms of how these are defined, and the use of the shared evidence base for the Black Country (Waste Study, 2020). The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-waste developments which do not prejudice existing waste-related operations.
We note that the Edwin Richards Landfill identified as a Strategic Waste Disposal Installation is also a proposed major housing allocation (allocation reference SH37) in the plan period. As this site is currently a recipient of relatively significant levels of waste from Dudley borough, we would welcome further information on the proposed timescales for its closure as part of our Duty to Cooperate discussions in respect of strategic waste matters.
Policy SWA3- Preferred Areas for New Waste Facilities
Dudley MBC supports the principle of this policy, which is consistent with draft Dudley Local Plan Policy DLP77 Preferred Areas for New Waste Facilities and is based upon a consistent evidence base for the Black Country (Waste Study, 2020). We note that the Sandwell Local Plan Policies Map identifies a ‘Preferred Area of Search’ for new waste facilities, which is a cross boundary area with Dudley borough at Bloomfield Road/Budden Road, Coseley. Whilst it is identified on the Policies Map, it is not listed in Table 13 of the supporting justification text to Policy SWA3 nor in Appendix E (where these sites are listed again). We would welcome clarification that the site is allocated and recommend it is included in the site-specific list of allocations within the SLP. Dudley MBC supports the principle of this allocation as it aligns with the draft Dudley Local Plan allocation detailed in Policy DLP77 and identified on the Policies Map. We would expect any site-specific proposals to take account of cross boundary considerations e.g., highway impacts, as part of the detailed planning application process.
We note that there are several housing allocations proposed within proximity of this preferred area (Bradleys Lane/High Street, Brown Lion Street, and The Boat Gauging House). We would expect these sites to have been assessed in terms of their potential to prejudice any existing and proposed waste operations at this location, taking account of cross boundary allocations and safeguarded sites within Dudley borough.
Policy SMI1- Minerals Safeguarding
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP80 Mineral Requirements and Policy DLP81 Mineral Safeguarding. The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-minerals developments which do not prejudice existing minerals-related operations. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic minerals matters, including via the West Midlands Aggregates Working Group and as part of the production of Local Aggregates Assessments for the West Midlands Metropolitan Area.
Appendix B- Sandwell Site Allocations (Mixed Use Allocation SM2 Lion Farm, Oldbury)
Dudley MBC would welcome further clarification in relation to Mixed Use Allocation SM2 Lion Farm, Oldbury. This represents a major allocation which is in proximity of Dudley borough and has potential cross boundary implications given its scale and current/proposed uses. The site currently provides for 6 sports pitches which have the potential for provide for cross boundary sports provision. The SLP states that appropriate uses are the retention of 6 sport pitches. The ‘Further Information’ text states that a net loss of the pitches could be avoided which is strongly caveated by the ability to relocate 6 pitches to the southern part of the borough. We would welcome clarification on whether the existing pitches are to be retained on site or relocated and if this would have any implications for cross boundary provision given the need to protect and enhance pitches across the Black Country. One of the Black Country Overarching Strategic Framework recommendations states the following for Football: Protect existing quantity of pitches, including lapsed and disused provision, until all demand is being met (unless replacement provision meets Sport England requirements and is agreed upon and provided).
The SLP states that the site will provide for 200 homes and 2.3ha of employment land. In respect of the employment land provision, we would welcome clarification if this site is proposed for B class employment use in accordance with SLP Policy SEC1. The site does not appear to be included within the B class employment land totals which are set out at Appendix C to the SLP (and already total the 29ha of vacant land referenced in SLP Policy SEC1). Dudley MBC would have concerns if this site was to be utilised for any large-scale retail development and the potential impact upon our own Tier One and Tier Two centres, plus additional impacts on highways. Any cross-boundary implications in respect of highways impacts should be fully considered. We would welcome confirmation on the specific proposals for the site.
Dudley MBC also notes the proximity of this site to the Edwin Richards Quarry site allocation (SH37). The cumulative impacts of these two allocations in terms of cross boundary infrastructure provision should be considered.

Thank you for the opportunity to comment on the draft Sandwell Local Plan (SLP). Our response is provided in plan order by individual SLP policies. Please note this represents an officer- level response at this stage, which is subject to formal Cabinet approval in 2024.
Overall, we support continued joint working and engagement under the Duty to Cooperate as our respective Local Plans progress and welcome further discussions to address the issues identified in our response.
Policy SDS1- Development Strategy
The key elements of this policy are supported by Dudley MBC, including the principle of delivering as much new development as possible on previously developed land and sites within the urban area. Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing and employment land supply currently identified. Please note our response to Policy SHO1 in respect of the housing land supply position.
The SLP identifies that Sandwell’s unmet housing and employment land needs will need to be provided for across the Housing Market Area (HMA), Functional Economic Market Area (FEMA) and other areas with which Sandwell has a physical or functional relationship. Reference is made to the latest position in respect of the Duty to cooperate with further information contained in the supporting Draft Plan Statement of Consultation (Duty to Cooperate Statement, 2023).
This Statement (at paragraphs 31-34) identifies that there are a series of ‘offers’ from other local authorities outside of the Black Country towards the unmet housing needs of the area. Dudley MBC agrees that this largely reflects the latest position, but there are some updates to take account of. The Dudley MBC Duty to Cooperate Statement (2023) at paragraph 2.27 notes that Telford and Wrekin Council has since published its Regulation 18 Local Plan (October 2023) with a potential contribution of 1,600 homes towards the Black Country’s unmet housing needs. The Lichfield Local Plan was withdrawn from Examination in October 2023. We would also note that Cannock Chase and South Staffordshire Councils’ previously paused work on their local plans following the Government’s proposed reforms to the national planning policy framework in December 2022. We are aware that work on both plans has recently recommenced.
The Sandwell MBC Duty to Cooperate Statement (at paragraph 34) states that discussions are ongoing in relation to how these contributions are disaggregated between the four Black Country authorities, which is also reflected within the Dudley MBC Duty to Cooperate Statement (paragraph 2.26). Dudley MBC has identified a housing supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC will therefore continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
In respect of unmet employment land needs, the Sandwell MBC Duty to Cooperate Statement (paragraphs 36-41) sets out the ‘offers’ from other local authorities, which reflects the information contained within the Dudley MBC Duty to Cooperate Statement (2023). It is recognised that this reflects the position as was the case for the Black Country Local Plan draft plan consultation stage (as of 2021). The latest position, as contained within the up-to-date Black Country Economic Development Needs Assessment (EDNA, 2023) and Black Country Employment Land Supply Paper (2023) and resulting from any future updates to relevant local authority contributions, will need to be reflected at the next stage (Regulation 19) of our respective Local Plans. Dudley MBC has identified an employment land supply shortfall, as detailed within our recent Regulation 18 Draft Local Plan, which it is similarly working to address via contributions from relevant local authorities under the Duty to Cooperate. Dudley MBC supports the principle of addressing the employment land shortfalls via the Black Country FEMA and will continue to work jointly with Sandwell MBC under the Duty to Cooperate to progress this matter.
For clarity, Dudley MBC is unable to contribute towards the housing and employment land supply shortfalls of Sandwell MBC.
In respect of the other strategic matters set out within the Sandwell MBC Duty to Cooperate Statement e.g., transport, natural environment, whilst it is recognised that here will be the key prescribed bodies to engage on these matters, Dudley MBC would welcome any cross-boundary considerations related to such topics also being reflected within forthcoming Statements of Common Ground between our authorities, as necessary.
Policy SDS2- Regeneration in Sandwell
Dudley MBC supports the SLP approach of focusing new development and regeneration within the identified Regeneration Areas and West Bromwich strategic centre.
The Regeneration Area of Dudley Port and Tipton relates to the draft Dudley Local Plan Regeneration Corridor 4 (the Regeneration Area of the Wednesbury to Tipton Metro Corridor is also of relevance). Dudley MBC supports references to the new public transport hub to be developed around the interchange of the Midland Metro Extension and Dudley Port railway station. Combined with the metro extension from Dudley town centre to Dudley Port, this will provide Dudley borough residents with enhanced access to the national railway network. Housing and employment development in this area is supported but should take account of any cross-boundary infrastructure requirements arising from specific proposals.
The justification to the policy references the opportunities to build upon the existing infrastructure, making the canals and greenspace a destination, linking to wider attractions such as the Dudley Canal Trust, Black Country Museum and Dudley Zoo. Recognition of these attractions and potential opportunities to enhance linkages to them is supported.
It is noted that £20million has been awarded from the Levelling Up Fund towards the regeneration of Tipton. Whilst the principle of the regeneration and redevelopment of such areas to deliver additional housing and employment growth is supported, specific proposals for the regeneration/redevelopment of the Owen Street District Centre (also known as Tipton Town Centre) should be of an appropriate scale to that centre so as not to detract from the functions of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy SDS5 – Cultural Facilities and the Visitor Economy
Dudley MBC supports references within the justification text to assets that are also within Dudley borough, including cross-boundary sites such as Bumble Hole and Warrens Park.
Policy SNE1- Nature Conservation
Dudley MBC supports references to the protection of Fens Pool Special Area of Conservation. We would expect this to be addressed as part of the Habitats Regulation Assessment process for the SLP and individual development proposals, as necessary.
Policy SNE2- Protection and Enhancement of Wildlife Habitats
The Biodiversity Net Gain site proposals include Warren Halls Park Strategic Open Space, which represents a cross boundary opportunity with Bumble Hole Nature Reserve within Dudley borough. Bumble Hole Local Nature Reserve is identified as a potential Biodiversity Net Gain Receptor Site within the draft Dudley Local Plan.
The draft Dudley Local Plan identifies the Saltwells Local Nature Reserve as a potential Biodiversity Net Gain Receptor Site, which borders onto Mousesweet Brook Local Nature Reserve/SINC within Sandwell borough. This site is not identified within the SLP as a Biodiversity Net Gain site. There may be an opportunity for cross boundary working in relation to this area if the site was identified within the SLP. Dudley MBC will continue to work jointly with Sandwell MBC to identify any such opportunities going forward.
Dudley MBC supports the use of the Black Country Local Nature Recovery Network Strategy to maximise cross boundary benefits.
Dudley MBC welcomes the opportunity to explore and share active travel link improvements along Mousesweet Brook, Mushroom Green and Black Brook leading to Cradley Heath transport interchange (rail/bus station).
Policy SNE4- Geodiversity and the Black Country UNESCO Global Geopark
Dudley MBC supports this policy, which is consistent with draft Dudley Local Plan Policy DLP35 Geodiversity and the Black Country UNESCO Global Geopark.
Policy SHE2- Development in the Historic Environment
The policy and the supporting justification text references the Black Country Historic Landscape Characterisation Study (2019) and the supporting justification text references that Areas of High Historic Landscape (AHHLV) and Areas of High Historic Townscape value (AHHTV) were identified as part of this study. However, these areas do not then appear to be reflected within the policy itself (in terms of specific reference to them) or identified on the SLP Policies Map. There is also no reference made to the other two Historic Environment Area Designations (HEADS) identified in the Black County HLC - Designed Landscapes of High Historic Value (DLHHV) or Archaeological Priority Areas (APAs). For consistency in the implementation of the shared Black Country evidence base, and in recognition of cross boundary considerations in relation to the historic environment, Dudley MBC would welcome further references to these designations within the policy and for them to be reflected on the Policies Map. This is particularly relevant for site allocations which border/are adjacent to the Dudley borough boundary.
Policy SCC4- Flood Risk
The supporting justification text references the primary sources of fluvial flood risk within Sandwell which need to be addressed and considered. This includes the River Stour which crosses into Dudley borough. Dudley MBC supports these references.
Policy SHO1 – Delivering Sustainable Housing Growth
It is noted that 11,167 net new homes will be delivered over the plan period (up to 2041) with 97% on brownfield land and 3% on greenfield land. The SLP prioritises the development of previously developed land. The Plan identifies that there is a resulting shortfall of 18,606 homes against a housing requirement of 29,773 homes. The draft SLP states that Sandwell MBC is in discussions with neighbouring authorities to seek their agreement to accommodate some of Sandwell’s unmet needs (at paragraphs 3.12-3.19).
Dudley MBC is supportive of the Council’s approach in terms of prioritising brownfield land development in the first instance and appropriate greenfield sites within the urban area. The approach to the review of urban capacity is generally supported, and the application of assumptions related to discounting of the housing land supply is largely consistent with that applied in Dudley borough. It is noted that the Council consider there are no exceptional circumstances for the release of Green Belt land to meet identified housing needs, including the housing supply shortfall.
Dudley MBC is supportive of Sandwell MBC maximising its urban area supply to meet its own housing needs as far as possible, particularly considering the scale of the current housing supply shortfall identified (representing around two thirds of the minimum housing requirement). Sandwell MBC should continue to keep its urban capacity under review to identify any further opportunities for new development that would contribute to the shortfalls in housing supply identified.
It is noted that the Council has explored opportunities for additional supply from its centres (West Bromwich, Town, District and Local Centres across the borough). This yields around 219 additional dwellings. Related Policy SHO3- Housing Density, Type and Accessibility states that the highest densities of 100+ dwellings per hectare representing apartment schemes will only be acceptable where accessibility standards set out in Table 6 are met and the site is located within West Bromwich. We would welcome clarification on whether schemes located outside of West Bromwich namely at the other town centres within the borough (as identified in Table 10 of the SLP) could also achieve such higher densities given their accessible locations.
Achieving higher densities within such locations could potentially yield additional urban supply, albeit it is recognised this is unlikely to be significant in the context of the scale of the housing supply shortfall. This would however be consistent with the approach set out under the former draft Black Country Local Plan (2021) Policy HOU2 where such densities were identified as appropriate for strategic and town centres. The draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility identifies hat the strategic centre of Brierley Hill and its other town centres at Dudley, Halesowen and Stourbridge are in principle suitable for such high-density developments (subject to local character considerations for individual schemes). Please also see our response to Policy SDS1 – Development Strategy in respect of matters related to the housing supply shortfall.
It is noted there are several major housing allocations proposed along/nearby the boundary with Dudley borough including:
• SH25- Bradleys Lane/High Street, Tipton (189 dwellings)- no planning permission.
• SH1- Brown Lion Street (27 dwellings)- planning permission.
• SH7- The Boat Gauging House and adjacent land (50 dwellings)- subject of planning application.
• Several allocations around Cradley Heath including: SH16- Cradley Heath Factory Centre, Woods Lane (196 dwellings)- partly subject of planning application; SH4- Lower High Street – Station hotel and Dunns site (20 dwellings)- no planning permission; SH13- Silverthorne Lane/Forge Lane (81 dwellings)- no planning permission; SH15- Mcarthur Road Industrial Estate (13 dwellings)- no planning permission.
• SH34- Brandhall Golf Course (190 dwellings)- subject of planning application.
• Whilst located near to Rowley Regis, given the scale of the proposed allocation at SH37-Edwin Richards Quarry (526 dwellings within the plan period and 100 dwellings post plan period, partly subject of planning permission/application for 276 dwellings) we also note the relative proximity of this site to Dudley borough.
These allocations should take account of cross-boundary infrastructure considerations given the potential for the cross-boundary use of and impacts upon highways, health, and education services. Matters related to impacts upon amenity and character of the local area should also be considered on a cross boundary basis. Dudley MBC would welcome the opportunity to be consulted on any future masterplans/other planning documents that may be produced for these sites going forward (and any planning applications, as appropriate). We would also welcome the opportunity to be engaged on the Infrastructure Delivery Plan that will support the SLP as its progresses to the next Regulation 19 stage so that any cross-boundary issues can be identified and addressed.
In respect of education provision specifically, we would note that historically for cross-border flow of pupils the largest flow for Dudley MBC is with Sandwell MBC. As such Dudley MBCs education team would welcome ongoing discussions in relation to housing allocations nearby the boundary including updates on the proposed delivery timescales and Sandwell MBCs position on the education provision for such schemes. We particularly note that the SH25 allocation at Bradley’s Lane and the various allocations around Cradley Heath are located closer to primary schools within Dudley borough than those in Sandwell.
In respect of transport matters specifically, all developments exceeding 150 dwellings (as compliant with Local Transport Note LTN 1/20) at or near the Dudley MBC boundary should be considered in terms of impact on the surrounding network and subject to traffic impact assessments. All new developments should be considered in terms of opportunities to deliver active travel, Community Infrastructure Levy funds, Section 106 contributions and access to bus rail and tram transport across local authority boundaries.
Policy SHO3- Housing Density, Type and Accessibility
This policy is largely consistent with the draft Dudley Local Plan Policy DLP11- Housing Density, Type and Accessibility. This is supported as it provides a consistent approach to sites which are in proximity to the Dudley borough boundary.
As per our comments on Policy SHO1, we would welcome clarification as to whether town centre locations within Sandwell could accommodate higher density developments of 100+ dwellings.
Policy SHO10- Accommodation for Gypsies, Travellers and Travelling Showpeople
Dudley MBC supports the proposed protection of existing authorised pitches (16 in total) and note that 10 new pitch allocations are proposed. The proposed allocation SG1 is nearby the Dudley borough boundary at Brierley Lane for 10 pitches, which would be an extension to an existing caravan site.
Dudley MBC would welcome clarification on the size of the existing site. As set out within the SLP supporting text (paragraph 7.71) there is generally a preference for family-sized sites of 10-15 pitches. As this allocation of 10 pitches represents an extension to an existing site, we would welcome clarification of the total eventual site size including existing and proposed pitches. We would be concerned with the delivery of a site whose scale is not well related to its surrounding area. Detailed proposals for this site should take account of any cross-boundary infrastructure issues arising and matters related to impacts upon amenity and character of the local area (including within Dudley borough).
The draft SLP policies are supported by the joint evidence base produced for the Black Country; the Black Country Gypsy and Traveller Accommodation Assessment (GTAA, 2022). We welcome the use of this jointly produced evidence base. The GTTA identified a need of eight pitches up to 2031 and an additional six pitches from 2031-2041 for Sandwell. The SLP will deliver ten pitches to meet the need up to 2031 plus a buffer of two pitches (20%) - providing a five-year deliverable supply of pitches from adoption of the SLP in 2025. The approach will provide 71% of the total need for 14 pitches over the Plan period (2023-41). The SLP states that it is not possible to identify and allocate further sites to meet the remaining need for four pitches up to 2041 as no deliverable site options were put forward through the Sandwell Local Plan preparation process. Therefore, this remaining need will be met within the borough through the planning application process. This is consistent with past trends, where small windfall sites have come forward within the urban area.
The GTAA identified a need for 32 Travelling Showpeople plots for Sandwell. The SLP states it is not possible to identify and allocate sites to meet this need as no deliverable site options have been put forward through the Sandwell Local Plan preparation process. Therefore, this need will also be met within the borough, through the planning application process (and is consistent with past trends for windfall sites).
Dudley MBC is supportive of Sandwell MBC seeking to meet its outstanding needs via the planning application process. For clarity, Dudley MBC is unable to contribute towards any unmet needs of Sandwell and has identified its own shortfall in Gypsy, Traveller and Travelling Showpeople provision within the draft Dudley Local Plan.
Policy SEC1- Providing for Economic Growth and Jobs
SLP Policy SEC1- Providing for Economic Growth and Jobs, identifies that the borough will provide at least 1,206ha of employment land. This consists of 1,177ha of occupied employment which is allocated as strategic, local or other employment land and 29ha of land that is currently vacant.
The SLP notes that the latest Economic Development Needs Assessment (EDNA, produced jointly in 2023 between the Black Country local authorities) identifies an employment land requirement of 185ha for Sandwell (2020-2041). The SLP (at paragraph 2.14) states that completions for 2020-2022 and the supply of land available for employment use totals 42ha, including a vacant land supply of 29ha. There is a resulting shortfall of 143ha against Sandwell’s employment land requirements. The SLP (at the supporting text to Policy SEC1) identifies that the shortfall will be addressed through the Black Country Functional Economic Market Area (FEMA) and that unmet needs should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with Sandwell. This work is ongoing under the Duty to Cooperate.
The general approach of the SLP towards employment land provision is supported by Dudley MBC, however we would note that the EDNA published as part of the SLP consultation is dated August 2023. The most up to date version of the EDNA is October 2023, which reflects the current employment land requirements and supply position for all the four Black Country local authorities. This identifies an employment land requirement of 186ha for Sandwell, which increases to 212ha if the replacement of employment land losses is accounted for (for information, the draft Dudley Local Plan Policy DLP18- Economic growth and job creation identifies that the need for the replacement of employment land losses, equivalent to 26ha for Dudley borough, will be monitored over the plan period). We would welcome confirmation that the most current version of the EDNA (October 2023) will be used to inform the next stage of the SLP.
Dudley MBC recommends that the text at current paragraph 2.14 is replicated in the supporting justification text to Policy SEC1 to clarify that the employment land supply for Sandwell is 42ha (2020-2041). We note that EDNA and the Black Country Employment Land Supply Paper (2023) identifies an additional supply of circa 78ha arising from large and small windfall sites within the Black Country which would further reduce the employment land supply shortfall (it is noted that this figure is not disaggregated to the local authority level at this time). The borough specific contribution from the West Midlands Strategic Rail Freight Interchange (as detailed in the Stantec report of 2021)1 can also be accounted for, as per the supporting text contained within the draft Dudley Local Plan in respect of this contribution from outside the Black Country. These additional sources of supply should be recognised within the SLP supporting justification text going forward.
The latest EDNA (October 2023) and Black Country Employment Land Supply Paper (October 2023) has informed the draft Dudley Local Plan. The evidence base has been produced jointly by the Black Country local authorities, reflecting the strong FEMA that exists. This evidence base identifies individual local authority employment land requirements as part of a wider Black Country requirement. It also applies this to the employment land supply. The Employment Land Supply Paper notes the contributions that have been secured to date from other local authorities towards the Black Country employment land supply shortfall, namely from Shropshire and South Staffordshire at this time. It is envisaged that these discussions will continue as the respective local plans progress and the latest position will need to be reflected in our respective Regulation 19 local plans.
We note that there is one employment site allocation nearby the Dudley borough boundary at Coneygre Business Park for 7.22ha (reference SEC1-5). This is situated in proximity of the Strategic Employment Area (Ionic Business Park) within Dudley. The proposals for the site should take account of any cross-boundary infrastructure considerations, particularly impacts upon key infrastructure such as highways.
This site is close to the A4123/borough boundary and depending on the nature of the development, increased traffic may impact on this key route which is currently being improved to facilitate both active travel and bus route enhancements. It remains a cross boundary joint improvement initiative including input from both local authorities, Black Country Transport and Transport for the West Midlands. Continued joint working in respect of any cross-boundary implications would be welcomed, including consultations on any planning applications, as appropriate.
Policy SEC2- Strategic Employment Areas, Policy SEC3- Local Employment Areas and Policy SEC4- Other Employment Areas
Dudley MBC supports the SLP approach to Strategic Employment Areas (Policy SEC2), Local Employment Areas (Policy SEC3) and Other Employment Sites (Policy SEC4). The policy approach is broadly consistent with that set out in the draft Dudley Local Plan.
We note that the followings areas are identified as Local Employment Areas (LEA), and we support these designations as they are consistent with cross boundary/adjacent sites to the boundary of Dudley borough:
• Brymill Industrial Estate (adjacent to Budden Road, Coseley LEA in Dudley)
• The Angle Ring Company Ltd (adjacent to Budden Road, Coseley LEA in Dudley)
• Bloomfield Park (adjacent to Budden Road, Coseley and Birmingham New Road LEAs in Dudley)
• Providence Street, Cradley Heath (adjacent to Westminster Industrial Estate LEA in Dudley)
• Cakemore Industrial Estate (adjacent to Cakemore Road LEA in Dudley)
• Station Road Industrial Estate (adjacent to Nimmings Road LEA in Dudley)
It is noted that the Coneygre Industrial Estate is identified as a Local Employment Area. This lies adjacent to Ionic Business Park within Dudley borough which is identified as a Strategic Employment Area. It is noted that this reflects the findings of the Black Country Employment Area Review (BEAR, 2021).
Policy SCE1- Sandwell’s Centres, Policy SCE6- Edge of Centre and Out of Centre Development, and Town Centre Profiles
Dudley MBC supports the use of the jointly produced Black Country Centre Study update (2021) evidence base for the SLP. The draft Dudley Local Plan also utilises this evidence base.
Dudley MBC is supportive of the general approach to Centres. We are supportive of the impact test threshold of 280sqm for edge or out of centre proposals, which is consistent with draft Dudley Local Plan Policy DLP27 Edge of Centre and Out of Centre Development (we note that the contents of Table 10 of the SLP would appear to require updating to clarify this is the approach i.e., that proposals of more than 280sqm require impact tests). The implementation of the SLP policies should ensure that the scale of proposals for growth within the centres is commensurate to their scale, role, function and order in the hierarchy, taking account of nearby centres outside Sandwell borough including those in Dudley.
In relation to this, we note that for the Tier Two town centre of Blackheath there appear to be no significant proposals for growth identified. Some redevelopment site opportunities are identified, but these are not significant in scale and are for mainly residential use. For the Tier Two town centre of Cradley Heath, similarly there are no significant proposals for growth identified, with mostly residential redevelopment site opportunities identified.
As outlined in our response to Policy SDS2, the principle of the regeneration and redevelopment of Owen Street District Centre (also known as Tipton Town Centre) is supported however any specific proposals should be at a scale appropriate to the District Centre so as not to detract from the function of higher order centres within the vicinity, including Dudley Town Centre (identified as a Tier 2 centre within the draft Dudley Local Plan).
Policy STR1- Priorities for the Development of the Transport Network
Dudley MBC supports this policy and there are several cross-boundary projects referenced, consistent with draft Dudley Local Plan Policy DLP67 The Transport Network. We are supportive of the reference to the Dudley Port Integrated Transport Hub, which will link into the Metro extension for Brierley Hill-Wednesbury and provide access to the national railway network for Dudley borough residents. The Council would welcome continued joint working on the relevant evidence base for transport matters, including transport modelling to address cross boundary matters consistently.
Policy STR2- Safeguarding the Development of the Key Route Network (KRN)
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP68 The Key Route Network. This ensures a consistent approach to cross boundary matters related to the KRN.
Policy STR4- The Efficient Movement of Freight and Logistics
Dudley MBC supports this policy which is broadly consistent with the draft Dudley Local Plan Policy DLP70 The Movement of Freight. This ensures a consistent approach to cross boundary projects related to this topic, including the reopening of the Stourbridge-Walsall-Lichfield railway line (as referenced at paragraph 11.38 of the SLP). The draft Dudley Local Plan also references this project (at paragraph 16.32).
Policy STR5- Creating Coherent Networks for Cycling and Walking
The approach is broadly consistent with the draft Dudley Local Plan Policy DLP71 Active Travel. Dudley MBC supports the principle of this policy and welcomes the opportunity to continue joint working on the delivery of relevant cross boundary projects, including:
• Birmingham New Road (A4123)/Burnt Tree (A461).
• Tipton Road (A4037)/Birmingham New Road (A4123).
• Birmingham New Road (A4123)/Sedgley Road (A457).
Management of major works at the following locations will be key to sustainable travel and minimising disruption across the network:
• Birchley Island (A4123)/Churchbridge (A4034) (in close proximity to Dudley borough).
• Wolverhampton Road (A4123)/Hagley Road West (A456) (in close proximity to Dudley borough)
to rail stations such as Dudley Port station (i.e., A4123/A461 scheme), Tipton rail station, Old Hill station & Coseley station will be very helpful to both Sandwell and Dudley borough residents.
Please also see our response to Policy SNE2- Protection and Enhancement of Wildlife Habitats in respect of opportunities for active travel links.
Policy STR8- Parking Management
Dudley MBC supports this policy which is consistent with draft Dudley Local Plan Policy DLP73 Parking Management. It helps to ensure a cross boundary consistent approach to this matter, which is of relevance in relation to strategic centre and town centre parking provision. We support the use of a shared Black Country evidence base to inform this policy. The most up to date Car Parking Study has been finalised and this, or any further updates, should inform the next stage of the SLP.
Policy SWA1- Waste Infrastructure Future Requirements
This policy is broadly consistent with draft Dudley Local Plan Policy DLP75 Waste Infrastructure- Future Requirements and is therefore supported in terms of consistency in addressing cross boundary matters.
It is noted that the updated supporting evidence base for Sandwell and SLP Policy SWA1 sets out the waste infrastructure capacity gaps for the plan period. The draft Dudley Local Plan and its supporting evidence base has also identified waste infrastructure capacity gaps, particularly for those facilities which the borough is unlikely to be able to accommodate due to its urban nature e.g., landfill, anaerobic digestion and composting facilities. Dudley MBC would welcome further discussions under the Duty to Cooperate in relation to cross boundary waste matters, particularly given the existing waste movements between our local authorities. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic waste matters, including via the West Midlands Resource Technical Advisory Body (WMRTAB).
Policy SWA2- Waste Sites
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP76 Waste Sites. Dudley MBC supports the identification of strategic waste sites, applying a consistent approach in terms of how these are defined, and the use of the shared evidence base for the Black Country (Waste Study, 2020). The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-waste developments which do not prejudice existing waste-related operations.
We note that the Edwin Richards Landfill identified as a Strategic Waste Disposal Installation is also a proposed major housing allocation (allocation reference SH37) in the plan period. As this site is currently a recipient of relatively significant levels of waste from Dudley borough, we would welcome further information on the proposed timescales for its closure as part of our Duty to Cooperate discussions in respect of strategic waste matters.
Policy SWA3- Preferred Areas for New Waste Facilities
Dudley MBC supports the principle of this policy, which is consistent with draft Dudley Local Plan Policy DLP77 Preferred Areas for New Waste Facilities and is based upon a consistent evidence base for the Black Country (Waste Study, 2020). We note that the Sandwell Local Plan Policies Map identifies a ‘Preferred Area of Search’ for new waste facilities, which is a cross boundary area with Dudley borough at Bloomfield Road/Budden Road, Coseley. Whilst it is identified on the Policies Map, it is not listed in Table 13 of the supporting justification text to Policy SWA3 nor in Appendix E (where these sites are listed again). We would welcome clarification that the site is allocated and recommend it is included in the site-specific list of allocations within the SLP. Dudley MBC supports the principle of this allocation as it aligns with the draft Dudley Local Plan allocation detailed in Policy DLP77 and identified on the Policies Map. We would expect any site-specific proposals to take account of cross boundary considerations e.g., highway impacts, as part of the detailed planning application process.
We note that there are several housing allocations proposed within proximity of this preferred area (Bradleys Lane/High Street, Brown Lion Street, and The Boat Gauging House). We would expect these sites to have been assessed in terms of their potential to prejudice any existing and proposed waste operations at this location, taking account of cross boundary allocations and safeguarded sites within Dudley borough.
Policy SMI1- Minerals Safeguarding
Dudley MBC supports the principle of this policy, which is broadly consistent with draft Dudley Local Plan Policy DLP80 Mineral Requirements and Policy DLP81 Mineral Safeguarding. The policy approach also helps to ensure cross boundary consistency in identifying appropriate locations for non-minerals developments which do not prejudice existing minerals-related operations. Dudley MBC will continue to work with Sandwell MBC on cross boundary strategic minerals matters, including via the West Midlands Aggregates Working Group and as part of the production of Local Aggregates Assessments for the West Midlands Metropolitan Area.
Appendix B- Sandwell Site Allocations (Mixed Use Allocation SM2 Lion Farm, Oldbury)
Dudley MBC would welcome further clarification in relation to Mixed Use Allocation SM2 Lion Farm, Oldbury. This represents a major allocation which is in proximity of Dudley borough and has potential cross boundary implications given its scale and current/proposed uses. The site currently provides for 6 sports pitches which have the potential for provide for cross boundary sports provision. The SLP states that appropriate uses are the retention of 6 sport pitches. The ‘Further Information’ text states that a net loss of the pitches could be avoided which is strongly caveated by the ability to relocate 6 pitches to the southern part of the borough. We would welcome clarification on whether the existing pitches are to be retained on site or relocated and if this would have any implications for cross boundary provision given the need to protect and enhance pitches across the Black Country. One of the Black Country Overarching Strategic Framework recommendations states the following for Football: Protect existing quantity of pitches, including lapsed and disused provision, until all demand is being met (unless replacement provision meets Sport England requirements and is agreed upon and provided).
The SLP states that the site will provide for 200 homes and 2.3ha of employment land. In respect of the employment land provision, we would welcome clarification if this site is proposed for B class employment use in accordance with SLP Policy SEC1. The site does not appear to be included within the B class employment land totals which are set out at Appendix C to the SLP (and already total the 29ha of vacant land referenced in SLP Policy SEC1). Dudley MBC would have concerns if this site was to be utilised for any large-scale retail development and the potential impact upon our own Tier One and Tier Two centres, plus additional impacts on highways. Any cross-boundary implications in respect of highways impacts should be fully considered. We would welcome confirmation on the specific proposals for the site.
Dudley MBC also notes the proximity of this site to the Edwin Richards Quarry site allocation (SH37). The cumulative impacts of these two allocations in terms of cross boundary infrastructure provision should be considered.

Duty to Cooperate

The Draft SLP notes that there is significant movement of waste into and out of Sandwell as follows:

‘13.20 The BCWS waste projections also considered net waste imports. Around 1.35 million tonnes of waste were received at permitted waste sites (including landfill sites) and operational incinerators in Sandwell in 2021 (BCWS Table 2.10). The total imports into Sandwell originating from the West Midlands Region was 746 tonnes, representing 68% of the total waste received.

[N.B. WMRTAB notes paragraph 2.8.7 of the updated Black Country Waste Study for Sandwell states that 'The total imports into Sandwell originating from the West Midlands region (excluding the waste originating in Sandwell) was 746,000 tonnes’ and so the ‘746’ value included in paragraph 13.20 shown above is an error.]

13.21 More than 80% of the waste received at permitted waste facilities in Sandwell (excluding incinerators) in 2021 by tonnage originated within the former West Midlands region (BCWS Appendix J, Table J4). However, the originating authority of 29.5% of this waste is not known. 15% of the waste is recorded as originating from within the Black Country, and 15% from Birmingham.

13.22 Similarly, more than 80% of the waste received at permitted sites in England which was recorded as having originated in Sandwell in 2021 (by tonnage) did not travel beyond the former West Midlands region. Outside the West Midlands, the East Midlands, Southwest and East of England were the three largest importers of waste into Sandwell, importing 9% of total waste.

13.23 In 2021 nearly 608kt of waste originating in Sandwell were exported to permitted sites in England and Wales.’

The distribution of waste arising in Sandwell to authorities in the West Midlands is set out in Figure 2.3 of the updated Back Country Waste Study for Sandwell (2023) 2 which is set out below: (See attached Letter)

In light of the above, WMRTAB notes that meaningful dialogue between Sandwell and other Waste Planning Authorities is likely to be important to ensure it meets its obligations under the Duty to Cooperate.

The Sandwell Duty to Cooperate (DtC) Statement (published November 2023),3 paragraph 61 ‘Effect of new development on waste disposal’, notes that ‘The Council has been involved in waste discussions through the West Midlands Resource Technical Advisory Body (RTAB), a body set up to support and promote cooperation between Waste Planning Authorities (WPAs) and others. The Council sent DtC letters out to those Waste Planning Authorities where waste movements were above the agreed thresholds for waste movements. Letters were set out on the 19th April 2023 and were followed up on the 25th May 2023. Staffordshire, Dudley and Walsall Councils consider the matter to be significant enough to warrant a SoCG, whereas Cheshire East and Chester Council would like further discussions on the matter’.

It is understood that engagement related to ensuring compliance with the DtC is ongoing and that application of the WMRTAB Duty to Cooperate protocol has revealed that there are very few waste movements to WPAs which exceed the 20% threshold for movement to one authority and there are no movements within the last year that exceed the 40% threshold. At this stage WMRTAB notes that whilst a DtC statement4 has been prepared this does not set appear to out the purpose of the DtC correspondence that has taken place so far and whether there were any outcomes, particularly in terms of whether the Local Plans of other areas allowed for, or would allow for, the meeting of any future unmet waste management capacity requirements that currently exist or might exit in the future in Sandwell. The inclusion of such information is not essential, however WMRTAB wish to draw attention to the Planning Inspectorate ‘Procedure Guide for Local Plan Examinations’ which includes the following (with emphasis added):

‘Has evidence to demonstrate compliance with the Duty to Co-operate been prepared?
1.15. In order to demonstrate compliance with the duty to co-operate (section 33A of the PCPA), the most helpful approach is for the LPA to submit a statement of compliance with the duty. The statement of compliance should identify any relevant strategic matters and how they have been resolved – or if they have not, why not. It should detail who the LPA has co-operated with and on which strategic matter(s), the nature and timing of the co-operation (e.g. by including meeting notes), and the outcomes of the co-operation, including how it has influenced the plan’

In any event it is recommended that the outcomes of the application of WMRTAB protocol to identifying strategic waste movements be documented. In this regard WMRTAB notes that it is important that information within the evidence base concerning the need for Duty to Cooperate engagement (and, if required, nature, reason and any outcomes of the engagement) is included to allow consultees to comment on whether engagement with other Waste Planning Authorities is necessary and, if it has taken place, whether this has been sufficient to meet the legislative requirements. WMRTAB appreciates that any dialogue may be ongoing and, in any event, is pleased to confirm that Sandwell Metropolitan Borough Council is an active member of WMRTAB and an officer from the Council regularly attends the group’s meeting and contributes to its work. WMRTAB has therefore facilitated discussion between Sandwell Metropolitan Borough Council and other neighbouring waste planning authorities to assist with meeting its Duty to Cooperate (DtC) on matters pertaining to the planning for waste management.

Planning for Sufficient Waste Management Capacity
Paragraphs 13.17 to 13.28 set out estimated arisings and whether capacity gaps (surpluses) will exist in future. This is essentially the key findings of the ‘Updated waste needs assessment to support preparation of emerging Local Plans for each Black Country Authority – Sandwell’. This report provides an updated assessment of the likely future waste management capacity gaps (and surpluses) for Sandwell based on 2021 data. WMRTAB notes that a previous study had been prepared in 2022 for the Black Country following advice from WMRTAB that waste needs assessments should be based on the latest available data. WMRTAB notes that more recent data, for 2022, is now available via the Environment Agency Waste Data Interrogator 2022 that was published in November.

WMRTAB notes that paragraph 13.17 of the Draft SLP states that ‘under current projections, the quantity of waste Sandwell is projected to manage increases from
1.75 mt in 2021 to 2.2 mt in 2040 – 41, equating to an increase of 26% or 1.2% per annum. An ongoing emphasis on waste reduction has seen a 7.5% reduction in waste per household since 2006 - 07 and this trend could have a significant influence on future waste growth. However, there are emerging changes in the need for different types of waste management capacity’.

Paragraph 13.20 of the Draft SLP states that ‘the BCWS waste projections also considered net waste imports. Around 1.35 million tonnes of waste were received at permitted waste sites (including landfill sites) and operational incinerators in Sandwell in 2021 (BCWS Table 2.10). The total imports into Sandwell originating from the West Midlands Region was 746 tonnes, representing 68% of the total waste received’. WMRTAB supports the recognition of Sandwell’s role in managing waste from other areas.

[see comment about the ‘746’ error above – this should read 746,000]

Paragraph 13.39 further notes that the ‘quantity of waste Sandwell is projected to manage (included imported waste) is predicted to increase from 1.75 million tonnes (mt) in 2021 to 2.1 mt in 2040-41, equating to an increase of 23% or 1.1% per annum. However, this does not appear consistent with data in paragraph 13.17 which states (inconsistencies highlighted):

‘Under current projections, the quantity of waste Sandwell is projected to manage increases from 1.75 mt in 2021 to 2.2 mt in 2040 – 41, equating to an increase of 26% or 1.2% per annum. An ongoing emphasis on waste reduction has seen a 7.5% reduction in waste per household since 2006 - 07 and this trend could have a significant influence on future waste growth. However, there are emerging changes in the need for different types of waste management capacity.’

WMRTAB recommends that the figures highlighted are checked to ensure they are consistent, or an explanation of the inconsistency is provided. In any event WMRTAB supports the approach to recognising waste imports in calculation of arisings to be planned for.

Future waste management ‘capacity gaps’ for the Black Country (Sandwell, Dudley, Wolverhampton and Walsall) are identified over the plan period. The Draft SLP states, at paragraph 13.26, that Table 4.9 of the Black Country Waste Study (BWCS) ‘predicts that the following additional waste management capacity will need to be delivered in the Black Country between 2021 and 2041 to maintain net self- sufficiency’:

a. re-use / recycling (non-hazardous municipal waste) – 813 kt to 4tpa [Note that a value of ‘4 tonnes per annum’ suggests that data is being presented with ‘spurious precision’ which national policy advises against].
b. energy recovery (residual municipal waste) – 335 to 663 kt tpa’

The BCWS (updated 2023) (Updated waste needs assessment to support preparation of emerging Local Plans for each Black Country Authority – Sandwell) identifies a range of waste management capacity gaps for recycling, recovery and landfill calculated using the following three scenarios:

Existing capacity is set out in paragraph 2.6.3 of the updated BCWS as follows: ‘in 2021 the capacity of permitted waste sites in Sandwell was estimated to be:
• Recycling and Recovery – 922,000 tonnes per annum
• Transfer – 394,000 tonnes per annum
• Inert Landfill – 0 cubic metres/ 0 tonnes
• Non-Hazardous Landfill – 5.6 million cubic metres/ 4.8 million tonnes
• Hazardous Landfill – 0 cubic metres/ 0 tonnes

…..This gives a total baseline capacity of around 6.1 million tonnes’.

The capacity gaps are identified in the updated BWCS as follows:

The commentary relating to Table 3.9 is set out in the following paragraphs which state (with emphasis added):

‘3.5.25 Table 3.9 shows us that the waste management capacity gaps over the Plan Period are more apparent for recycling sites under WMS option 2 and 3 as more waste is sent for recycling in line with government targets. There is also a capacity deficit for recovery sites up until 2025 over all three options, more so for WMS3; however, after 2025 extra recovery capacity comes online and there is no longer a recovery deficit. Given the internal increase in waste sent for recycling, and the reduced requirement on waste sent for recovery, it is expected that waste imported for recovery to be slightly higher under WMS2 than WMS3. Under WMS3 the internal demand for recovery capacity is higher with less waste sent for recycling, but the recovery projections for C&D waste are higher under WMS2 option. There is sufficient disposal capacity over most of the plan period under all three options, in particular under WMS2 and WMS3 as less waste is sent for disposal. From 2039 onwards however, WMS1 has a disposal deficit closely followed by WMS2 and WMS3 in 2040’.

3.5.26 Housing growth will put pressure on existing household waste management capacity, and as this is largely managed outside Sandwell under current contractual arrangements this is an important focus going forward. Sandwell may also need to accommodate some of the waste capacity requirements of other waste planning authorities, especially as they are a net importer of waste, putting greater pressure on an already saturated waste management infrastructure capacity.

3.5.27 There are limited options for residual waste disposal with few quarries in Sandwell likely to come forward for restoration by infilling with inert or non-hazardous waste during the Plan Period. There are also limited options for CD&E waste recycling and organic waste treatment; there are no composting or anaerobic digestion facilities within the area.


3.5.28 In order to achieve ‘net self-sufficiency’ Sandwell would be expected to provide for extra waste capacity of the types it can in theory accommodate (e.g. re-use, recycling, MRS, energy recovery, waste treatment, inert and non- hazardous landfill) to make up for the types of waste capacity it cannot accommodate because of being a largely built-up area (e.g. composting, AD, hazardous landfill).

WMRTAB notes that capacity gaps are therefore identified in the updated BWCS, however it has the following observations:

1. Due to the use of different terms, it is not absolutely clear how the capacity gaps identified in Table 3.9 translate to the capacity it is stated could be accommodated (in theory) in Sandwell in paragraph 3.5.28; and,
2. while the capacity gaps are clearly set out on the updated BWCS they are not clearly stated in the Draft SLP.

WMRTAB recommends that the Draft SLP should clearly state and indicate how the quantum of additional capacity, of each different waste management capacity type is being planned for by the SLP. In particular, the SLP should state clearly what the future requirement for landfill capacity will be and how that requirement is to be met. This should include any expectation that waste to be managed by landfill will be exported to other areas.

Notwithstanding the fact that the maintenance of net self-sufficiency (in terms of provision for waste management) appears to have been taken into account in the estimates of capacity gaps, it is not included as an objective within the Draft SLP. For the avoidance of doubt, WMRTAB consider that such an objective should be clearly included within the SLP.

Locations for Waste Management
WMRTAB notes that no specific sites for new waste management facilities have been allocated in the Draft SLP. Paragraph 13.47 (Identification of Preferred Sites) states: ‘it is not proposed to allocate specific sites for waste in the Local Plan because no new sites likely to be deliverable within the plan period have been identified, apart from sites that already have planning permission (NPPF, 16, 35, Annex 2). To have sufficient confidence to allocate a site, it would need to be actively promoted for a waste management use by the Council, a landowner and / or a commercial waste operator’.

However, paragraph 13.38 of the Draft SLP states: ‘The identification and delivery of new waste management facilities will make a significant contribution towards meeting new capacity requirements set out above and will meet the aims and objectives of the Plan.’

Policy SWA3 states: ‘The preferred locations for waste management facilities are the Local Employment Areas shown on the Sandwell Local Plan Policies Map.’

Paragraph 13.57 goes into further detail explaining that (with emphasis added): ‘Several broad locations suitable for the development of new waste management facilities in Sandwell have been identified in Table 13 of Policy SWA3’

WMRTAB acknowledge that the choice of the ‘Preferred Areas’ identified in the BWCS ‘as being most suited to the development of new waste recovery, treatment, and transfer infrastructure’ was based on a series of locational considerations and constraints to identify the most appropriate likely future location for new waste facilities.

WMRTAB understand Sandwell has undertaken numerous Call for Sites exercises during the preparation of the current Local Plan and as part of its involvement in the former Black Country Plan.

WMRTAB acknowledges that the approach of not allocating specific sites reflects the local circumstances/nature of the Black Country whereby waste sites frequently feature within general employment areas across the urban area and these are located within large urban areas that are constrained in terms of opportunities for new developments overall. WMRTAB recommends that the approach, of not allocating specific sites and relying on general areas and areas of employment land, be robustly justified within the evidence base.

Landfill
Although at the bottom of the waste hierarchy, non-hazardous landfill is still an important type of waste management that needs to be planned for and WMRTAB notes that there is little consideration of this matter in the Draft SLP, with no mention how non-hazardous landfill would be planned for.

A report prepared for WMRTAB on landfill in the West Midlands indicates the following for 2019:

There are five landfill sites for inert, non-hazardous & hazardous waste in the Black Country. At the end of 2019, active inert landfill capacity was estimated at 690,000 (m3), non-hazardous LF capacity estimated at 11,666,401 (m3) and non-hazardous LF capacity with SNRHW cell estimated at 418,953 (m3). Landfill sites have been allocated in Walsall which allow a further increase inert landfill capacity of 3,000,000 (m3) in future.

WMRTAB notes that it is important that the future management of waste requiring disposal is planned for in the SLP and recognises that this should be resolved via the ongoing Duty to Cooperate engagement.

Waste management development considerations
WMRTAB generally supports the development considerations set out in Policies SWA1, SWA2, SWA3, SWA4 and SWA5 in relation to employment areas, minimising harm to human health and the environment, and other impacts of waste management proposals such as on surrounding buildings, resources and constraints on development.

WMRTAB suggests that the meaning of Policy SWA1-Waste Infrastructure Future Requirements could be clarified. Currently this states (with emphasis added):

‘Waste Infrastructure Future Requirements:

1. Proposals for relevant, major development shall evidence how its operation will minimise waste production, as well as facilitating the re-use and recovery of waste materials including, for example, through recycling, composting and energy from waste.
2. Waste operators will be expected to demonstrate that the greenhouse gas emissions from the operations involved and associated transport of waste from source to processing facility have been minimised, in line with national and local targets for the transition to a net zero carbon economy.
3. Proposals for waste management facilities will be supported based upon the following principles;
a. managing waste through the waste hierarchy in sequential order. Sites for the disposal of waste will only be permitted where it meets a need which cannot be met by treatment higher in the waste hierarchy;
b. promoting the opportunities for on-site management of waste where it arises and encouraging the co-location of waste developments that can use each other’s waste materials;
c. ensuring that sufficient capacity is located within Sandwell to accommodate the waste capacity requirements during the plan period and reducing the reliance on other authority areas;
d. enabling the development of recycling facilities across Sandwell, including civic amenity sites, and ensuring that there is enough capacity and access for the deposit of municipal waste for re-reuse, recycling, and disposal;
e. waste must be disposed of, or be recovered in, one of the nearest appropriate facilities, by means of the most appropriate methods and technologies, to ensure a high level of protection for the environment and public health;
f. ensuring new waste management facilities are located and designed to avoid unacceptable adverse impacts on the townscape and landscape, human health and well-being, nature conservation and heritage assets and amenity;
g. working collaboratively with neighbouring authorities with responsibilities for waste who import waste into, or export waste out of, Sandwell, to ensure a co-operative cross boundary approach to waste management is maintained.

Firstly, regarding clause 1, the term ‘relevant major development’ has not been defined. WMRTAB suggest additional clarity could be provided within the SLP to make it clearer what ‘relevant major development’ consists of and so therefore what type of proposal would this part of the policy apply to. Point 1. Also states that there is a need to demonstrate how ‘operation’ of the facility will ‘minimise waste production’, however, the construction phase seems to have been not considered within the policy whereas this is frequently a source of significant quantities of waste.

Part 2 of the policy expects that greenhouse gas emissions will be minimised ‘in line with national and local targets for the transition to a net zero carbon economy’, however there is no indication of what these targets are and so it is recommended that information be included to provide clarity and in turn allow proper implementation of the policy.

WMRTAB strongly supports part 3, clause ‘g’ of the policy, however the extent to which Sandwell will rely on other areas in future to meets its needs and how it is meeting the capacity requirements of other areas it is not clear with the Draft SLP (see comments above concerning the Duty to Cooperate) but WMRTAB recognises that this should be resolved via the ongoing Duty to Cooperate engagement activity.

Safeguarding
Paragraph 13.39 of the Draft SLP states that the ‘The Sandwell Local Plan is a strategic plan and therefore it focuses on safeguarding strategic waste sites.
The approach of protecting existing/safeguarding waste facilities from other development which may impact on their operation is implemented by Policy SWA2 (Waste Sites). WMRTAB notes that this is an important consideration, especially in an area where it is difficult to find suitable land for waste management development. In addition, it is further noted, in paragraph 13.25, that: ‘The Council will look to identify development sites for waste infrastructure, with priority placed upon the safeguarding of existing and allocated sites for continued use.’

Policy SWA2 states that (with emphasis added):
1. Sandwell will safeguard all existing strategic and other waste management facilities from inappropriate development, to maintain existing levels of waste management capacity and meet Strategic Objective 17, unless it can be demonstrated that:
a. there is no longer a need for the facility; and
b. capacity can be met elsewhere; or
c. appropriate compensatory provision is made in appropriate locations elsewhere in the Black Country; or
d. the site is required to facilitate the strategic objectives of the Sandwell.

2. This policy will also apply to all new waste management sites that are implemented within the lifetime of the plan.

New development near existing waste facilities

3. Proposals for housing and other potentially sensitive uses will not be permitted near to or adjacent to an existing waste management site where there is potential for conflict between the uses,


a. unless a temporary permission for a waste use has expired, or the waste management use has otherwise ceased, and the site or infrastructure is considered unsuitable for a subsequent waste use;
b. or redevelopment of the waste site or loss of waste infrastructure would form part of a strategy or scheme that has wider environmental, social and / or economic benefits that outweigh the retention of the site or infrastructure for the waste use and alternative provision is made for the displaced waste use;
c. or a suitable replacement site or infrastructure has otherwise been identified and permitted.
4. Waste Site Impact Assessments will be expected to demonstrate that at least one of the above criteria applies. Applications should also identify any 'legacy' issues arising from existing or former waste uses, and how these will be addressed through the design of the development and the construction process.

WMRTAB generally supports the approach in the Draft SLP to safeguarding existing waste management capacity but has the following observations:

• Clause 1 of Policy SWA2 mentions ‘other waste sites’ but it is not clear what these are. Should this make it clear that this means all other waste sites which are allowed to operate by planning legislation?
• The identified ‘strategic waste sites’ and ‘other waste sites’ appear to have the same level of safeguarding protection and so it is unclear why a distinction has been made between strategic and other waste sites. If the intention is to safeguard all waste sites, regardless of whether they are considered strategic or not, then WMRTAB recommend that the policy states this clearly.
• Clause 1. d. appears to introduce a contradiction as the ‘strategic objectives’ include Draft SLP Strategic Objective 17 that states: ‘To manage waste as a resource and minimise the amount produced and sent to landfill, including ensuring that the reliance on primary minerals during construction and development are kept to a minimum and that greater use is made of recycled or alternative building materials’. In addition, paragraph 13.2 outlines ‘the key objective for waste across Sandwell is to minimise its generation across all sectors and increase the re-use, recycling, and recovery rates of waste material.

Other matters
Policy SCC4 – Flood Risks, identifies waste (and mineral) facilities as the only types of development where all such proposals would require a flood risk assessment and surface water drainage strategy as outlined below:

‘7. All new developments in the following locations should be accompanied by a flood risk assessment and surface water drainage strategy that sets out how the development will provide a betterment in flood risk terms i.e., help to reduce flood risk both on and off site:…

• where the site is a minerals or waste development;’


While proposals for certain types of waste facilities may need such assessment, WMRTAB suggest that the Draft SLP check whether this blanket approach is justified.

The Reg 18 Sandwell Local Plan – Reg 18 Consultation Spatial Strategy Paper (published November 2023), Corporate Plan Objectives includes the objectives as set out in paragraph 3.6 below.
‘Para 3.6 The objectives summarised below for the Core Strategy sought to deliver the Vision by 2026 and promoted: -
i. Sufficient waste recycling and waste management facilities in locations’

WMRTAB suggest that the text regarding the year 2026 above needs to be re- checked as the SLP period is until 2041.

Comments submitted in table form
Para 72 Consider re-phrasing and celebrating the industrial heritage of the area and how that has shaped the local identity of the area.
Para 73 Amend to ‘Registered Parks and Gardens’.
Consider amending heritage conservation areas to conservation areas and the setting of heritage assets or something similar.
Heritage assets themselves are ‘irreplaceable’ and should be conserved and protected and the Local Plan to provide a ‘positive strategy’ for this.
Their need to be protected is more than a recognition of their past use but as how heritage has shaped our identity and how they continue to remain relevant today and can contribute positively to the economy and social wellbeing.

It would be useful in this section if heritage can also be referenced as a component of landscape.
Page 29 Ambition 1 would benefit from a reference to the historic environment and recognising the benefits the historic environment can bring to a community and an area.

Ambition 2 would benefit from a reference to the historic environment and recognising the benefits the historic environment can bring to a community and wellbeing.

Would be worthwhile to check through the ambitions to consider where the historic environment would best be suited.


Page 33/34 We support the vision and the reference to heritage within it. We would welcome a reference to a wider variety of heritage such as heritage landscape/ archaeology etc. rather than a narrower definition of built heritage.
Objective 4/5 We are very supportive of specific objectives that seek to protect the historic environment. We would welcome a reference to heritage landscape and features and ensuring the wide range of historic environment is fully reflected and considered within the Plan.
Objective 15 We support the reference to heritage within this objective.
Para 2.18 We support this paragraph.
Para 2.30 clause C We support this clause.
Policy SDS1 clause j This could be amended to read conserve and enhance the significance of the historic environment, heritage assets and their settings through xxx to ensure that it is the significance of heritage assets that is being considered and protected through the policy text.
Policy SDS2 This policy would benefit from reference to the historic nature of the area and its heritage assets and how conserving the historic environment will be a benefit for the regeneration of the area. It would also be useful to reference the Wednesbury High Street Action Zone during the text regarding regeneration in Sandwell and the benefit of heritage led regeneration programmes. This would help meet the aims of the Plan mentioned earlier in the text. We note a brief reference in paragraph 3.42.
Policy SDS3 clause a) i)

d) We would request re-phrasing of this clause as sites submitted during a Call for Sites exercise will not necessarily be suitable for development. We would request that this is also re-phrased in any other policies that this statement may appear.

Could make reference to the historic environment.
Policy SDS4
Clause 2)

Clause 3)


Clause 9)
We support this reference and recommend additional detail in the Plan on how this can be achieved.

Confusing wording, we would request that this is amended yet we support the principle that the significance of heritage assets including their setting will be protected and it would benefit from a clearer form of words. Also consider re-wording paragraph 3.61.

Historic England are available to engage in this work.
Policy SDS5 clause 11) We support the reference to heritage tourism and welcome its inclusion in the policy, as well as in the justification paragraphs.
Section on Green and Blue Infrastructure from page 74 onwards We would welcome a reference to the historic environment as a component of green and blue infrastructure and the role heritage plays in this area. If you have any questions we are happy to answer.
Policy SDS7 We would request a clause to be included in this policy regarding the historic environment and its function within Green/ Blue Infrastructure.
Policy SNE4 We welcome a policy on the UNESCO Geopark and recognition of the important cultural heritage of the area and the contribution it has made in historical terms. Clause 1) consider re-phrasing to ensure that the significance of the asset and its integrity is fully protected and conserved for future generations.
Policy SNE5 This policy would benefit from strengthening the reference to the historic environment context of the area, including non designated heritage assets and heritage features as well as the heritage components of landscape.

Policy SNE6 We support the recognition of the historic nature of canals as heritage assets/ role within the wider cultural heritage agenda and welcome reference within the policy and justification text in this area.

Section 4, from page 113
We welcome a specific section on the historic environment and specific policies for the historic environment. We welcome the introductory paragraphs to the interesting, rich and varied history of the Black Country and the need to protect this and the value placed on heritage led regeneration.

Para 4.114
Consider the wording in this paragraph and also needs reference to the setting of heritage assets as well as an understanding of the context in which they are in and any relationships they may have with other heritage assets within the area/ heritage landscapes etc.

When considering a suite of policies for the historic environment, it is important to ensure that all the policies are consistent and that all assets are fully supported.

SHE1
We welcome the inclusion of this policy. We would request that there are some amendments to the wording to ensure it is compliant with the National Planning Policy Framework (NPPF), paragraphs 199 to 205 particularly. Heritage assets are an ‘irreplaceable resource’ and efforts should be made to ensure that the significance of heritage assets, including their setting are protected. The policy wording in clause 1 and 2 can be strengthened to reflect this. The wording in clause 3 is welcome and we are supportive of the need for Heritage Impact Assessment. The assessment should also set out the level of harm, how harm can be avoided or mitigated against and any opportunities for enhancement. Clause 4, setting in itself is not a heritage asset but it should be included within the section on significance and can still be a reason for refusal where the setting contributes to the significance of an asset, but will be affected by proposed development. Recording the loss of any heritage asset/ features on the Historic Environment Record (HER) would also be beneficial to include within this policy. Consider the wording for clause 5 to ensure the protection of a Conservation Area. We would recommend deleting clause 6. Paragraph 4.121 relates to this paragraph also.

SHE2

Similar to comments above, ensure that the policy is NPPF compliant and that it seeks to protect and conserve the historic environment and sets out where applications will be refused. As referenced the historic environment is an ‘irreplaceable resource’ and the NPPF sets out clearly how to deal with harm and how if necessary to apply the tests of harm. Clause 1 for example requests that heritage informs proposals and is considered; there should be a clause that states that harm to heritage will be refused unless xx. Again, clause 2 refers to the need to inform proposals which is beneficial, yet there needs to be wording inserted to prevent harm to the historic environment and conserve their significance, including setting.

Where ‘historic assets’ are referenced this should be amended to state ‘heritage assets’.
Clause 3, heritage assets should be protected as set out in the NPPF and relevant legislation.

Clause 5, delete ‘aim’. The policy wording should be strengthened to ensure that heritage assets are protected and conserved in Sandwell. The examples used are useful and provide a context for the type of heritage within the Borough; it would be beneficial to ensure that this describes some examples only and reference the relevant heritage evidence base that prospective developers will need to consider in full.

It would be beneficial to have a clause that relates to the need for appropriate qualified individuals undertaking assessment work, that the Historic Environment Record should be considered as a minimum, that views analysis is a useful tool to consider in the wider process etc. for all proposals which could affect heritage.


Para 4.123
Delete ‘ancient’.

It would be useful to provide some additional information about what a heritage impact assessment could include.
SHE3
Consider referring to significance generally in this clause. It would be useful to have a link to the Sandwell Local List. We are supportive of a Local List and welcome this.

SHE4
Considering re-phrasing the opening clause to ensure that the significance of archaeological heritage assets are protected and where possible enhanced.

Development proposals which cause harm to heritage assets should be refused unless the specifications set out in the NPPF are met. We consider that the wording should reflect this. There also needs to be consideration of non designated archaeology that could be of national significance. Ensure that heritage assets are referred to in line with the relevant clauses of Section 16 of the NPPF. A separate clause for archaeological investigation would be useful and to set out how it applies to heritage assets. Any archaeological investigation should be carried out by an appropriate and qualified professional and a programme of works agreed by the Council’s archaeology officer. A separate clause for recording would be beneficial. Clause 5 we would anticipate that all relevant information would be provided for the Council to assess the level of harm and to then make an informed decision within the context of the requirements of the NPPF.

4.133/34
Additional information would be beneficial.
Consider re-ordering the policies to have a historic environment policy first, and then specific policies on asset type, where relevant.

Section 5 Historic England are supportive of a section on Climate Change within the Plan. We enclose a link to some relevant publications considering the historic environment and climate change that may be useful to understand in the context of the Local Plan.

https://historicengland.org.uk/advice/climate-change/

Under this section it would be useful to consider how the historic environment can contribute to the climate change agenda, which measures are appropriate in the context of the historic environment and how heritage assets need to be considered. There may also be times when climate change proposals such as solar farms or wind turbines may not be an appropriate solution if it affects the significance of heritage assets and other areas may be more suitable for this technology.

Policy SCC1 We welcome clause j). It could relate to heritage assets more widely.
Policy SCC2 Clause 4 is useful. It may need to be stated that development which causes harm will be resisted or other solutions sought.

Policy SCC3 Clause 2, consider the potential impacts for the historic nature of canals and ensure that this is protected and conserved.

Policy SCC4 It would be useful to incorporate a clause on the historic environment within this policy and the specific considerations for the historic environment.

Policy SCC5 It would be useful to incorporate a clause on the historic environment within this policy and the specific considerations for the historic environment.

Policy SCC6 We would recommend re-phrasing to state protects the significance of the historic environment, heritage assets including their setting or similar wording.

Policy SHW4 We support the reference to heritage within clause 8.

Policy SH01 We have not been able to comment on the specific housing proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SHO2 Clause 2) c amend to will not cause harm to the significance of heritage assets, including their setting or similar.
Policy SH010 We have not had the opportunity at this time to comment on the site allocations specifically. We would request that any proposed allocations consider the impact on the historic environment and ensure that where there is harm for the historic environment that an appropriate heritage impact assessment is available as an evidence base to support a proposed allocation.
Policy SEC1 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SEC2 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SEC3 We have not been able to comment on the specific employment proposals at this time, we will consider these in the new year and would welcome a meeting with the Council to understand how the historic environment has been considered. If there are any proposed allocations which could cause harm to the significance of heritage assets, including their setting, we would expect to see heritage impact assessment.
Policy SCE1 This policy would benefit from a clause relating to the historic environment, heritage led regeneration, heritage led public realm improvements, information relating to shop fronts and design within heritage centres and conservation areas and reference to Wednesbury High Street Heritage Action Zone and other potential opportunities.
Para 9.161 Are there any proposals within the Plan to address this?
Para 9.283 onwards We welcome the inclusion of this section in the Plan. Are there any tools or opportunities from this project that could be replicated elsewhere in the Borough?
Policy SWB1 This policy would benefit from a clause on the historic environment.
Policy STR1 How has the historic environment been considered in the process of highlighting transport infrastructure needs? Have any assessments been undertaken about the potential for harm to heritage assets, as a result of proposed transport initiatives?
Policy STR2 Comments above apply.
Policy STR6 Is there any information available at present about potential park and ride sites?
Policy SWA1 We would recommend re-phrasing clause 3) f to ensure that the policy protects the significance of heritage assets including their setting and inappropriate waste developments will be resisted. The policy may further benefit from some additional text on this issue in the reasoned justification text.
Policy SWA3 We have not been able to comment on specific proposed waste sites at this time. We will assess these in the new year and would welcome a meeting with the Council to discuss proposed allocations and any impacts these may have on the historic environment. If any proposed allocations could impact on the historic environment, we would expect to see a heritage impact assessment as evidence base.
Policy SWA4 This policy would benefit from a clause on the historic environment.
Policy SMI1 Are there minerals sites that are being proposed for allocation or safeguarding? If so, how has the historic environment been considered in this process?
Policy SMI2 Clause 5) b should set out an approach for what happens if a mineral working site is not appropriate due to the harm to the historic environment or if there are mitigation measures required to overcome any harm. The clause for cumulative impacts could also apply for the historic environment where there are already approved mineral workings in a historic landscape.

The policy would benefit from a clause on remediation so that the long term future of any minerals working site is appropriate in its environment.

Para 13.012 This para would benefit from additional detail.

SDM1 Clause g) we welcome reference to the historic environment within this policy and would request that ‘historic assets’ are amended to ‘heritage assets’ and that the significance of heritage assets including their settings are protected and where possible, enhanced.

Policy SDM3 Does the Council have any evidence base relating to tall buildings and which has been/ could be used to inform locations which may be appropriate or may not be appropriate for tall buildings? We have concerns about the impact of this policy on the historic environment and the historic nature of the area and are keen to understand if there is more information available at this time that has considered these issues?

With reference to both tall buildings and gateway sites, we are unclear what has informed the policy and what the policy is seeking to achieve.

Policy SDM5 It would be useful to include a section on the historic environment and what is appropriate in the context of heritage assets including conservation areas and listed buildings.