Sandwell Local Plan - Reg 19 Publication

The Local Plan (at paragraph 3.15) 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. This will be addressed under the Duty to Cooperate.

Paragraphs 15-18 of the Local Plan refer to the ongoing work under the Duty to Cooperate with further information contained in the supporting Duty to Cooperate Statement (September 2024). Dudley MBC considers the approach taken via the Local Plan process is legally compliant and sound.

Dudley MBC supports the Local Plan references to the ongoing work under the Duty to Cooperate to address the housing and employment land shortfalls identified across the Black Country Authorities to date. Dudley MBC has identified its own housing and employment land supply shortfalls within the Regulation 19 Dudley Local Plan (October 2024) which will also need to be provided for across the HMA and FEMA (Dudley MBC is therefore unable to contribute to the housing and employment land shortfalls of other local authorities). Dudley MBC and Sandwell MBC continue to engage and work jointly on the preparation of the Statements of Common Ground referenced in the Local Plan (and in the supporting Duty to Cooperate Statement (September 2024)).

Dudley MBC supports the principle of apportioning the housing contributions between individual local authorities within the HMA. As set out within the supporting Duty to Cooperate Statement (September 2024) the methodology for apportionment is in the process of being agreed. Dudley MBC supports the principle of addressing the employment land shortfalls via the Black Country FEMA.

Dudley MBC agrees that Table 1 sets out the current position in relation to potential housing and employment land contributions for the Black Country Authorities. We would note that the employment land contribution from Shropshire would not be disaggregated between the Black Country Authorities (as per the approach to the South Staffordshire employment land contribution).

Whilst we are supportive of the Local Plan approach taken to date, and the current commitment to agreeing the methodology for apportionment, we also note that at this stage of the Plan process Statements of Common Ground are still to be agreed, including the methodology for apportioning housing supply contributions. As such Dudley MBC would wish to appear at the Examination to discuss any matters arising around the Duty to Co-operate and Statements of Common Ground in relation to housing and employment land contributions, particularly if the position as set out in the current Local Plan changes going forward.

Dudley MBC considers the policy to be sound. The key principles of the policy are supported by Dudley MBC, including delivering as much new development as possible on previously developed land and on sites within the urban area (including appropriate greenfield sites) and increasing densities. Dudley MBC is supportive of Sandwell MBC maximising its urban area supply to meet its own growth needs as far as possible, and the approach taken by the Council for identifying land supply within the borough to date is supported.

Sandwell MBC should continue to keep its urban capacity under review over the plan period to identify any further opportunities for new development that would contribute to the land supply shortfalls currently set out (please see our separate response to paragraph 3.12/3.17).

Additional wording should be included at the end of paragraph 3.12 as follows:

The Council will continue to regularly monitor the land supply position and keep under review any opportunities for additional supply with the borough over the plan period. Mechanisms for such monitoring and review include an annual Strategic Housing Land Availability Assessment (wherein density and other capacity assumptions can be reconsidered and a Call for Sites undertaken); the Brownfield Register; forthcoming Design Codes, Masterplans or any equivalent for specific areas or sites; the Housing Delivery Test Action Plan (where applicable); and the Authority Monitoring Report.

Additional wording should be included at the end of paragraph 3.17 as follows:

This work includes those mechanisms set out at paragraph 3.12 to monitor and review land supply within Sandwell borough.

The approach taken by the Council for identifying land supply within the borough to date is supported, however the Local Plan recognises that the remaining housing shortfall within Sandwell is significant, and it outlines a shortfall may remain even when contributions from other local authorities are accounted for. Given this context, it is appropriate for Sandwell MBC to keep under review its own land supply on a regular basis and continue exploring opportunities for increasing the supply wherever possible. This would ensure the Local Plan is sound in terms of being ‘effective’ and ‘consistent with national planning policy’.

Additional wording should be included at the end of paragraph 3.12 as follows:

The Council will continue to regularly monitor the land supply position and keep under review any opportunities for additional supply with the borough over the plan period. Mechanisms for such monitoring and review include an annual Strategic Housing Land Availability Assessment (wherein density and other capacity assumptions can be reconsidered and a Call for Sites undertaken); the Brownfield Register; forthcoming Design Codes, Masterplans or any equivalent for specific areas or sites; the Housing Delivery Test Action Plan (where applicable); and the Authority Monitoring Report.

Additional wording should be included at paragraph 3.17 as follows:

This work includes those mechanisms set out at paragraph 3.12 to monitor and review land supply within Sandwell borough.

Dudley MBC considers the policy to be sound. Dudley MBC supports the Local Plan 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 Regulation 19 Dudley Local Plan (October 2024) Dudley-Coseley Regeneration Corridor 5 (and the Wednesbury Regeneration Area is also of relevance in relation to the Metro corridor). 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.

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.

Dudley MBC considers the policy to be sound. Dudley MBC supports this policy, including the reference to ‘at least 10,434 new homes’ (our emphasis added). However, please also see our response to paragraphs 3.12/3.17 which seeks additional references to an ongoing review of the housing land supply position.

Dudley MBC considers the policy to be sound. The Local Plan policy is informed by the most up to date shared evidence base; the Black Country Gypsy and Traveller Accommodation Assessment (GTAA, 2022). Dudley MBC supports the use of this jointly produced evidence base.

It is noted there is one allocation for 10 pitches proposed near the boundary with Dudley borough (site reference SG1, Brierley Lane). Detailed proposals for this site via future planning applications should take account of any cross-boundary infrastructure issues arising and matters related to impacts upon amenity of the local area (including within Dudley borough).

Dudley MBC supports Sandwell MBC seeking to meet its remaining needs for pitches and plots via the planning application process. As set out in Duty to Cooperate discussions between the local authorities, 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 Regulation 19 Dudley Local Plan (October 2024).

Dudley MBC considers the policy to be sound. Dudley MBC supports the overall approach of the policy. The Local Plan policy is informed by the most up to date shared evidence base; the Economic Development Needs Assessment for the Black Country Authorities (EDNA, October 2023). Dudley MBC supports the use of this jointly produced evidence base.

Dudley MBC supports ongoing joint working to address the employment land needs of the Black Country Functional Economic Market Area (FEMA) as per our response to Paragraphs 15-18 of the Local Plan (Duty to Cooperate).

It is noted that elements of the Sandwell employment land supply have been slightly updated since the last version of the Black Country Employment Land Supply Paper (November 2023) was published e.g., the inclusion of Lion Farm (site reference SM2) as an employment land allocation. Dudley MBC welcomes continued joint working to produce an up-to-date shared evidence base for the employment land supply across the FEMA.

Dudley MBC considers the policy to be sound. Dudley MBC supports the Local Plan policies for Strategic Employment Areas (Policy SEC2) and Local Employment Areas (Policy SEC3) as they provide cross-boundary consistency with proposals set out in the Regulation 19 Dudley Local Plan (October 2024). They are informed by the most up to date shared evidence base; the Black Country Employment Area Review (BEAR, 2021). Dudley MBC supports the use of this jointly produced evidence base.

Dudley MBC considers the policy to be sound. Dudley MBC supports the Local Plan policies for Strategic Employment Areas (Policy SEC2) and Local Employment Areas (Policy SEC3) as they provide cross-boundary consistency with proposals set out in the Regulation 19 Dudley Local Plan (October 2024). They are informed by the most up to date shared evidence base; the Black Country Employment Area Review (BEAR, 2021). Dudley MBC supports the use of this jointly produced evidence base.

Dudley MBC considers the policy to be sound. Dudley MBC supports this policy and the references to cross-boundary projects, which are consistent with the Regulation 19 Dudley Local Plan (October 2024) Policy DLP67 The Transport Network. Dudley MBC supports 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 Local Plan is informed by the most up to date shared evidence base; the Black Country Transport Modelling Report (October 2024). Dudley MBC supports the use of this jointly produced evidence base.