Part One: Spatial Strategy and Policies (Regulation 18)

6. Infrastructure

Introduction

6.1 A key role of the Dudley Local Plan (DLP) is to plan for the growth required for a sustainable and prosperous borough. Ensuring effective delivery of development will require strong collaborative working, both between the local authority and jointly with public, private and third sector partners, involving a robust process of infrastructure planning and delivery.

6.2 The provision of appropriate infrastructure in a timely manner underpins the transformational and regeneration strategy of the DLP and these policies are intended to ensure the delivery of all spatial priorities.

6.3 The National Planning Policy Framework (NPPF) highlights that advanced, high quality and reliable communications infrastructure is essential for economic growth and social wellbeing. It requires planning policies and decisions to support the expansion of electronic communications networks, including next generation mobile technology and full fibre broadband connections. The expansion of these networks in Dudley Borough will support the vision and spatial strategy of the Plan by supporting economic growth and sustainable development.

Delivery Constraints

6.4 Physical and social infrastructure is necessary to enable and support the growth required over the Plan period. New housing and economic development will put pressure on existing services and utilities but may also create opportunities to provide robust and innovative infrastructure solutions.

6.5 The DLP will be supported by an Infrastructure Delivery Plan (IDP) at the Regulation 19 stage, which will draw upon a range of evidence including transport modelling, a Utilities Infrastructure Capacity Study, a Water Cycle Study, and a Viability and Delivery Study. This evidence underpins the DLP by identifying infrastructure investment required to support development, potential constraints to delivery and the key delivery mechanisms and partners.

6.6 The DLP adopts a brownfield-first approach to maximise delivery of development within the urban area; however, poor ground conditions that are a legacy of the Dudley's mining and industrial past are a significant constraint, in both physical and financial terms. Therefore, tackling significant and structural delivery constraints are a priority for interventions, as they affect much of the development land supply in the urban area. The Council is working in partnership with the West Midlands Combined Authority, to ensure that brownfield land is prioritised for development and funding intervention.

6.7 Where valuable mineral resources are present, and it is viable to extract them as part of a remediation scheme, this may also help offset the costs.

Transport and Access to Residential Services

6.8 Parts of Dudley's existing highway infrastructure suffers from congestion. The transport modelling evidence is available to view alongside the plan and updated transport modelling work is ongoing, and this evidence will be available to inform the Plan as it progresses. Assuming that proposals for improved public transport, walking and cycling are delivered, it is not anticipated that the development of new housing and employment land will have a significant additional impact.

6.9 Most new housing development in the urban area will enjoy good accessibility, including to sustainable modes of transport, centres of employment, schools, shops, health facilities and other residential services. This should help to reduce the requirement for additional travel and will also help mitigate the impact of development.

6.10 Infrastructure investment will be required to support development, including:

• public open space
• transport provision
• school places
• health facilities
• affordable housing
• sustainable drainage systems
• wastewater treatment
• waste management

6.11 Changes may be required to the way that Dudley is powered over the Plan period, together with an increasing reliance on digital solutions. Where gaps in service provision exist, service providers are aware of them and will work to address them.

Economic activity

6.12 As identified in the Economic Development Needs Assessment (EDNA), the Black Country comprises a clearly defined functional economic market area (FEMA) with strong employment and labour market links to a hinterland with Birmingham and South Staffordshire districts. It is a fast-growing functional economy and has the capacity to deliver significant growth, given the diversity, resilience and concentration of key national sectors located in the area. However, skills' challenges are holding it back.

6.13 Economic development strategies including the Strategic Economic Plan (SEP) and Local Industrial Strategy seek to address these challenges to accelerate the growth of the local economy and there are major investment plans in the Black Country – including for the transport infrastructure which is crucial to meeting the ambitions in the West Midlands Strategic Economic Plans.

6.14 Considerable investment is taking place in the Black Country including the delivery of projects within Dudley Borough through working with the West Midlands Combined Authority. Some key projects that will take place over the life of the DLP include the regeneration of Dudley Town Centre, and many of these projects are, and will, benefit from funds such as:

• Devolved Housing Deal
• Levelling Up Funds
• Towns Fund
• Future High Streets
• Transport settlements including City Regions Sustainable Transport Settlement (CRSTS)

6.15 Other infrastructure likely to be delivered before and during the plan period are:

• The rollout of a fast-charging network for electric vehicles, ensuring that drivers will never be further than 30 miles from a rapid charging station
• 5G (and further generations) rollout

Planning Obligations

6.16 Planning obligations currently deliver local infrastructure improvements necessary to mitigate the impact of development on the local area. Examples include affordable housing provision, access improvements, open space and residential services.

6.17 Financial viability has always impacted on the extent of planning obligations that can be secured in in Dudley, particularly in areas suffering from poor ground conditions. The DLP will be introducing requirements for sustainable design and to adapt to and mitigate against climate change. As informed by the Viability and Delivery Study¹, viability impacts will vary according to the size, type (i.e., greenfield or brownfield) and location (e.g., whether the site is within a low or high value area) of the sites involved, and it is likely that interventions may be necessary to bring forward development on some of the more constrained sites within lower value areas.

6.18 The Community Infrastructure Levy (CIL) provides opportunities for local authorities to generate contributions for local and sub-regional infrastructure through a levy on a wide range of developments. This can present opportunities to provide a range of infrastructure currently beyond the scope of planning obligations: The Council has an adopted CIL charging regime, which has been endorsed by the Viability and Delivery Study.

Infrastructure Provision

6.19 The following policy sets out how the Council will secure infrastructure provision from future planned development. It also sets out the requirement for viability evidence where, in exceptional circumstances, proposals are unable to comply with the policies of the DLP.

Justification

6.20 The scale of growth proposed in the DLP will have impacts on the local environment and the capacity of a range of infrastructure and facilities. It is important that the appropriate investment takes place to ensure, future development is sustainable. The definition of infrastructure in this context, for which overall targets and standards are set in the DLP and national planning policy is wide, including:

1. affordable housing
2. renewable energy
3. publicly accessible open space
4. sustainable drainage
5. sport and recreational facilities
6. biodiversity net gain
7. transport, including active travel
8. air quality mitigation measures; and
9. residential services

6.21 These requirements are set out in more detail within the appropriate sections of the DLP, with related policies and guidance contained in Supplementary Planning Documents/ Supplementary Plans. Policy requirements set out in the DLP have been subject to a proportionate assessment of viability to ensure that those requirements are realistic, and the cost of meeting the needs of relevant policies will not undermine the deliverability of the Plan. Each development proposal must address its own impacts through on-site and offsite provision or enhancements, secured through planning obligations or other relevant means.

6.22 Analysis suggests that education infrastructure needs arising from the proposed DLP growth are likely to be accommodated via expansions to the current school estate as opposed to the creation of new school(s). However due to the DLP plan period extending beyond current education forecasts this analysis would be ongoing, and contributions may be required.

6.23 Similar to education provision, analysis is suggesting that additional GP consulting rooms may be required in certain areas of the borough depending on the scale and nature of those developments. Consultation with key infrastructure providers will be conducted throughout the planning process in order to determine if contributions are required on a site-by-site basis.

6.24 Where the combined impact of several developments creates the need for infrastructure, it may be necessary for developer contributions to be pooled to allow the infrastructure to be secured in a fair and equitable way. Pooling may take place both between developments and also between Dudley and other local authorities where there is a cross-authority impact.