Part One: Spatial Strategy and Policies (Regulation 18)

9. Employment

Introduction

9.1 The policies in this section are concerned with promoting and supporting employment in manufacturing, research, and development (Use Class E(g)(ii), E(g)(iii) and B2), warehousing (Use Class B8) and other uses that are appropriately located in industrial employment areas. Offices (Use Class E(g)(i)) are not classed as an employment use for the purposes of these policies: they are covered by policies DLP24-DLP30, which relate to uses that are more appropriately located in town centres.

9.2 An agenda for economic growth is reflected in the ambitions of the relevant national and regional strategic documents on this subject, especially:

• the National Planning Policy Framework (NPPF), which states that significant weight should be placed on the need to support economic growth and productivity, taking into account local business needs and wider opportunities for development, and that planning policies should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth.
• the West Midlands Combined Authority (WMCA) "Plan for Growth (2022)" which states that WMCA will deliver economic growth through new powers over economic development, transport investment, investing in skills and working with investors, and committing to net zero targets, especially around suitable employment clusters, including aerospace, electric vehicles and battery technology, and logistics and distribution, delivered through levers for growth, including developing future skills pathways and securing direct competitive funding.
• the West Midlands Local Industrial Strategy (2019) which sets out a path for raising productivity via several key employment sectors.

9.3 Previous economic growth strategies related to the former Black Country Local Enterprise Partnership (now defunct) such as the 'Black Country Strategic Economic Plan' (2014) and the 'Black Country Economy of Together' (2021) have effectively been subsumed by the regional WMCA strategies.

9.4 This growth agenda, when transposed at a local (Dudley) level, underlies the importance of meeting borough wide employment land needs expressed in strategic targets, including the projected demand for jobs from existing and future working age residents. This builds on Dudley's rich industrial heritage and adapting the existing portfolio of industrial land within the borough to provide the right environment, flexibility and interventions to encourage investment, especially in sustainable and progressive businesses. It provides a framework for meaningful long term employment opportunities and the creation of a prosperous, and economically strong and more sustainable borough.

9.5 In recognition of the strong economic functional relationships between the Black Country Authorities, the Council has continued to work in partnership with the other Black Country Councils to update the economic evidence base (for the Functional Economic Market Area- see further details below). The evidence base for the employment land policies primarily consists of a four stage Economic Development Needs Assessment (EDNA), and the Black Country Employment Area Review (BEAR). The EDNA 2023 (update) provides an up-to-date objective assessment of the industrial land needs for the Black Country, apportioned between the Black Country Authorities to 2041, based upon an independent assessment of the area's economic development needs.

9.6 The key conclusions of the EDNA studies are:

1. the Black Country is a clearly defined geographical unit, but with strong employment and labour market links to a hinterland that includes south Staffordshire, north Worcestershire, Birmingham, and Solihull.
2. the Black Country has been hit hard by the COVID-19 recession but is expected to recover strongly and has the capacity to deliver significant growth, given the diversity, resilience and concentration of key national sectors located in the area.
3. even pre-COVID19, recent growth was achieved against a backdrop of a weak local skills base, low business start-up rates and low GVA per head in comparison with the West Midlands and UK averages.
4. the Black Country employment land supply in 2020 was largely that inherited from the Core Strategy and the suite of Tier 2 Plans which supported it and is dominated by small sites in the urban area.
5. going forward, attracting high-growth knowledge-based industries in line with SEP ambitions will require the provision of more prestigious sites, high-quality space with easy access to key transport hubs and good connectivity.
6. the Plan also needs to ensure that Dudley Borough can accommodate a variety of business needs, including start-ups and smaller businesses - this means that a mixed portfolio of sites will need to be made available, including larger and smaller sites and spaces (including areas of both higher and lower specification).
7. it is imperative to protect the existing supply of land to meet future needs that will arise from a high growth-driven economy.
8. there is a significant gap between the employment land supply, inherited from the Core Strategy and subsequent Tier 2 Plans, and forecast future needs.

9.7 To address these issues, the strategy that underpins the Employment Land Policies is made up of the following elements:

1. to facilitate the growth and diversification of the economy, the Plan allocates land for new development within Dudley Borough, to accommodate jobs and output growth (Policy DLP18).
2. to accommodate a variety of business needs including high technology manufacturing and logistics sectors, the Plan provides for a balanced portfolio of sites (Policy DLP18).
3. to protect and enhance land and premises within existing employment areas where this provides for the needs of jobs and businesses (Policies DLP19, DLP20, DLP21).
4. to recognise that some sites will become unsuitable for continued employment uses and to facilitate their redevelopment to alternative uses including housing (Policy DLP21).
5. to enable local communities to share the benefits of economic growth (DLP23).

9.8 In terms of Dudley's specific employment land needs, the evidence contained within the latest Black Country Economic Development Needs Assessment (EDNA) 2023 provides an overall target figure for the Black Country area from 2020 to 2041 (470 hectares (ha) or 22.38ha per annum) with the target figure for Dudley Borough being 72ha or 3.42ha per annum.

9.9 This target figure has been evidenced through past employment land completions between 2001-2020 and is based upon the high rate of past completions scenario. Review of market intelligence data in the last five years (i.e., employment land enquiries) indicates that for Dudley MBC it is the high rate of past completions scenario that better reflects demand trends for the future.

9.10 The target figure of 72ha for Dudley (2020 to 2041) is based on past completions and, therefore, a split for manufacturing uses and logistics/storage and distribution has not been given within the EDNA. However, based on assumptions made within OE forecasts, it is estimated that 22.32ha is required for manufacturing uses and 48.96ha is required for storage and distribution uses (based on 32% Manufacturing and 68% Distribution and Logistics).

9.11 Within the EDNA, that overall employment land need figure for the Black Country is stated to increase to from 470ha to 533ha to take on board the employment land lost as a result of planned redevelopment to alternative uses. In Dudley, that total target figure of 72ha is increased to 98ha by adding in 26ha associated with those sites comprising existing operational employment land which are allocated for housing. The need for the replacement of such losses will be monitored as the Plan is implemented.

Spatial Strategy Plan: Employment

Providing For Economic Growth and Jobs

9.12 This policy seeks to ensure a sufficient quantum of development opportunities are provided to meet the demand for economic growth and support the diversification of the Dudley economy.

Justification

9.13 The NPPF specifically states that for forecasting future trends:

1. Plan makers should consider forecasts of quantitative and qualitative need (i.e. the number of units and floorspace for other uses needed) but also its unique characteristics (e.g. the footprint of economic uses and proximity to infrastructure), with the key output being an estimate of the scale of future needs, broken down by economic sectors.
2. Local authorities should develop an idea of future needs based on a range of data that is current and robust. Authorities will need to take account of business cycles and make use of forecasts and surveys to assess employment land requirements.
3. Emerging sectors that are well-suited to the area being covered by the analysis should be encouraged where possible - market segments should be identified within the employment land under consideration.
4. The available stock of land should be compared with the particular requirements of the area so that gaps in local land provision can be identified.

9.14 To contribute towards meeting the evidenced need for Dudley of 72ha of land for employment development for the period up to 2040, the Plan allocates 24ha of employment land for the period between 2020 – 2041, identified as Employment Opportunity Sites (EOS) on the Policies Map, with that figure also factoring in completions since 2020. To ensure that such sites make an effective contribution towards meeting needs, EOS shall be safeguarded for industrial employment uses within Use Classes E(g) (ii), E(g) (iii), B2 and B8, with consideration given to restricting development to those suitable uses through the application of appropriate planning conditions.

9.15 Further contributions to the supply of land to meet that need are likely to come forward through the redevelopment, intensification, conversion and enhancement of existing employment areas and premises, including the development of small opportunity sites (sites between 0.25 ha and 0.4 ha). However, while small sites can provide a constant supply of developable land, in overall terms, historically they have shown to have made a limited contribution to the delivery of overall development needs, and the availability of such sites can also be difficult to predict. As set out in the EDNA (2023) there is an assumption that small sites (less than 0.4ha) can deliver at least 1.1ha, giving a total supply of 25ha. This source could yield further supply over the Plan period and will be monitored accordingly.

9.16 Current evidence states 47ha or 65% of employment land need (not including replacement of employment land losses) arising in Dudley cannot be met solely within the borough[6]. This unmet need should be exported, as far as possible, to authorities that have a strong existing or potential functional economic relationship with Dudley, for example in terms of migration patterns, commuting links and / or connectivity through physical infrastructure such as rail and motorway. These are authorities evidenced as, primarily, being within the same Functional Economic Market Area (FEMA) as Dudley – the Black Country FEMA - and also those authorities outside of the FEMA, which have strong or moderate economic relationships with Dudley.

Figure 9.1 The Black Country FEMA

9.17 Details of the Black Country FEMA are shown in the above Figure 9.1 The FEMA for the Black Country, as set out within the 2017 EDNA and confirmed within the 2022 EDNA update, comprises the Black Country Authorities, with identified areas of strong economic transaction with the Black Country: South Staffs; Birmingham, and areas of moderate economic transaction with the Black Country: Wyre Forest; Bromsgrove; Solihull; Tamworth; Lichfield; Cannock Chase. Dudley's strongest FEMA relationships with exporting LPAs outside of the Black Country, based on net migration patterns, are with Wyre Forest and Bromsgrove.              

9.18 The work to export unmet need is ongoing, through the Duty to Cooperate process, and evidenced through relevant Statement of Common Ground. However, given that South Staffordshire District is an area of strong economic transaction with the Black Country, and that authority has been generally able to demonstrate a surplus of employment land to meet its needs, the siting of the West Midlands (Strategic Rail Freight) Interchange (WMSRFI) near J12 of the M6 and within that district, has been the subject of an assessment by (consultants) Stantec (2021 report), to determine how much land could be exported to neighbouring authorities with strong functional economic ties with South Staffordshire.

9.19 That report evidenced that 14 ha from the total 193 ha can be directly apportioned to Dudley to meet its needs. Given the robustness of this evidence that figure of 14 ha can be considered as a commitment towards contributing to Dudley's employment land supply, which given the offer of WMSFRI as Europe's largest new logistics development site, can be directly attributed towards Dudley's logistics need total.              

9.20 It is recognised that as there are a limited number of vacant, brownfield sites, which are appropriately sized and located to be considered as EOS, then an emphasis needs to be placed not only on the churn of land and premises within existing employment areas to contribute towards meeting Dudley's need, but also the renewal and rejuvenation of those employment areas so as to ensure that they become areas which can adapt to accommodate long term, sustainable economic development, particularly in providing premises for those companies involved with modern, cutting edge technologies and provide an opportunity to meet future growth needs.              

9.21 In order to align with and progress the objectives of the Plan aimed at the regeneration of the urban environment, a priority for the renewal of existing designated employment areas should be where such areas fall within designated Regeneration Corridors. It is also considered that suitable interventions be aimed at environmental enhancements, the incorporation of sustainable energy, drainage and transport measures, as well, where appropriate, the opening up of employment areas so that they are better integrated in with local communities which they serve: e.g., a tap house associated with a brewery.