Dudley Borough Local Plan Scoping Consultation Document

Ends on 10th September 2026 (56 days remaining)

9. Developing options for the spatial strategy

What are the key considerations in developing the options?

The plan will need to consider what options there are for sustainable development within the borough over the plan period and decide upon a preferred final ‘spatial strategy’ for the amount, type and location of future development. The spatial strategy will need to consider the following:

a) the overall development needs of the borough (e.g., the needs for housing, employment and other commercial uses).

b) the extent to which these development needs can then be accommodated within the borough taking account of local considerations, such as land availability and environmental constraints. This gives the development requirement.

c) the distribution of development, which is where and how that development will take place e.g., the supporting infrastructure required.

This will be informed by the following:

a) National planning policy (and supporting guidance).

b) The Plan’s Vision and ‘measurable outcomes’ related to the Vision (reflecting local considerations).

c) Local environmental constraints (affecting the suitability of land for development within the borough).

d) The availability and viability of land for development (including deliverability) taking account of local issues.

This section provides an overview of these factors and sets out how the Council intends to start developing the options for the spatial strategy. It takes account of the existing evidence base (including the Dudley Local Plan) and the changing national planning policy context. A key thread running through these is the need to ensure sustainable development in environmental, economic and social terms.

National planning policy and guidance: The key implications of the national planning policy context for potential high level spatial options for future development within the borough are considered in Appendix 2. Many of the implications remain the same between the extant 2024 NPPF and draft 2025 NPPF, however there are some differences in relation to Green Belt policy. National planning policy and guidance sets out the minimum local housing needs (according to the standard method for calculating local housing needs) which the Council must use. Other needs including those for gypsy and travellers, employment land and other commercial uses (such as retail) are established using locally produced evidence but drawing upon national policy and guidance for preparing these needs assessments.

Plan Vision: The Vision for the new Dudley Borough Local Plan will draw upon the Dudley Local Plan vision, updated as necessary to reflect changes to the national and local context, policy and guidance. Many elements of the existing Vision are still considered relevant to the new Local Plan. This includes the continued need to focus on regeneration and meet the borough’s development needs as far as possible whilst ensuring its unique natural and historic environment assets are protected, conserved and enhanced. The Vision and outcomes will also relate to matters such as the local housing needs of specific groups e.g., affordable housing and older persons housing, and the infrastructure necessary to support sustainable development. The range of topics covered by the Vision will need to be considered in the development of spatial options for future development.

Local environmental constraints (land suitability): The borough context is one of a largely urban authority that is relatively constrained by its existing built development up to the borough boundaries and surrounding urban areas. There are areas of undeveloped Green Belt and non-Green Belt land within, adjoining and outside the urban areas, however these are relatively limited. As noted in the baseline data section above, many are the subject of environmental designations (natural and historic) and/or serve important recreational purposes. This geographical context limits the spatial strategy options available for the new Local Plan i.e., a ‘new town’ is not an option for the borough.

Availability and viability of land (including deliverability): Based on the plan position and the new calculations for local housing needs outlined above, at this stage it is identified that the borough has a shortfall in its housing and employment land needs. Further development sites beyond that identified within the Dudley Local Plan will need to be considered in accordance with the most up to date national planning policy context. This will be informed by what land is ‘suitable’ (see above paragraph), ‘available’ i.e., willing landowners and/or developers, and the viability of land for development. It is recognised that the viability situation within the borough is challenging, particularly in specific areas of the borough and on brownfield sites. However, as part of the evidence base for the Dudley Local Plan it was recognised that the Council and its partners, such as the WMCA and Homes England, is working effectively to utilise regeneration funding to address such challenges. Related to viability is the overall deliverability of new development i.e., new development within the borough will need to be supported by the appropriate infrastructure.

What are the key steps for developing the options?

To develop spatial options for the borough, the Council considers that the following steps will need to be considered, in accordance with existing national planning policy and reflecting the local context (including the current position from the Dudley Local Plan). These steps are not necessarily sequential; they may be undertaken simultaneously to one degree or another.

The borough context is one of a predominately urban authority but with undeveloped areas of both non-Green Belt land (within the urban area) and Green Belt land (within and outside the urban area). As summarised in Appendix 2 national planning policy requires local authorities that contain Green Belt land to consider whether there are ‘exceptional circumstances’ for altering Green Belt boundaries (paragraph 146 of the NPPF, 2024). These circumstances include where an authority cannot meet its identified need for homes, commercial or other development through other means. Before concluding ‘exceptional circumstances’ exist, the Council should fully examine all other reasonable options for meeting its identified need for development (paragraph 147 of the NPPF, 2024). The plan strategy should:

make as much use as possible of suitable brownfield sites and underutilised land;
optimise the density of development; and
be informed by discussions with neighbouring authorities about whether they could accommodate some of the identified development needs.

The steps outlined therefore reflect this current national planning policy position and the local context. A similar position is reflected in the draft NPPF (2025) albeit with some changes in respect of references to discussions with neighbouring authorities and consideration of land around railway stations. Any changes to the national planning position and its impact upon the drawing up of spatial options for the borough will need to be considered at the time of the updated NPPF.

In developing and assessing the spatial options, a key consideration will be the Local Plan Vision and measurable outcomes i.e., how does the option serve to deliver the overarching ambitions for the borough to ensure locally distinctiveness sustainable development.

Table 3: Key steps for developing the options

Key Steps	Key Considerations alongside the Key Steps
Step 1. Consider baseline position – land supply from the Dudley Local Plan) and the potential shortfall against updated development needs for the new Local Plan Current housing land supply of 10,937 dwellings results in a substantial shortfall against the 2024 local housing needs (circa 12,000 dwelling shortfall over a 15-year plan period). Employment land supply of 12.5ha results in a shortfall against the Dudley Local Plan needs- updated employment needs assessment to take place for the new Local Plan to establish updated position. MHCLG draft guidance^[11] states that local authorities should assume that sites that are existing plan allocations or that have planning permission are suitable, available and achievable for development. These sites do not need to be assessed unless there is evidence to suggest that circumstances may have changed that would require further assessment.	National Planning Policy and guidance e.g., for calculating local housing needs and other development needs; for development densities; site selection; mix of development sites; steps for demonstrating ‘exceptional circumstances’. Existing Local Plan housing and employment land supply and sites- review where necessary in line with national guidance. The Local Plan Vision and measurable outcomes (how will the spatial options help to deliver local priorities and ambitions). Local environmental considerations (the suitability of land for development). Local land availability, viability and deliverability.
Step 2. Explore the potential for additional supply from the existing urban area and brownfield land This could be undertaken by revisiting densities (seeking to optimise them further, wherever possible) and exploring any previously discounted sites, in accordance with national planning policy. The Council will need to consider any ‘gateway constraints’ to the development of sites within the existing urban area e.g., sites which are the subject of environmental designations (see Step 4 and related questions below). Council to explore the potential to use emerging digital tools for land searches and site assessment could assist in identifying additional.
Step 3. Engage with neighbouring and other relevant local authorities (part of shared housing and economic market areas) to understand the wider housing and employment land supply and shortfall considerations and implications for Dudley. Work for the West Midlands SDS is likely to inform this step (alongside any other relevant emerging SDSs) in terms of cross-boundary development needs and land supply. Discussions to include whether any of Dudley’s development needs could be met outside of the borough (in accordance with national planning policy). As part of the Dudley Local Plan contributions from other local authorities towards housing and employment land shortfalls in Dudley and the Black Country were considered. These contributions were however identified in a different context e.g., local housing and employment needs at the time and based on those other local authorities’ emerging local plans. Further discussions will be required to understand the latest position in respect of the contributions from other local authorities. It is noted that the scale of current contributions identified to date would not address the housing and employment land supply shortfalls identified in Dudley (set out at Step 1).
Step 4. Consider the potential for additional development sites outside the urban area to inform options for the spatial strategy Following work under Steps 2 and 3, should a shortfall in meeting development needs still be identified then additional land supply options will be considered. This includes considering sites outside the existing urban area on greenfield land (and any brownfield land outside the urban area not already considered in Step 2). This includes land within the Green Belt. Potential for emerging digital tools for land searches and site assessment to assist in identifying additional sites There are areas of undeveloped Green Belt and non-Green Belt land within the borough that are protected via other designations, which are likely to be considered ‘gateway constraints’ e.g., nationally designated environmental and heritage assets. This reduces the scope of options for the overarching spatial strategy and individual sites that can be considered for future development. The Council considers that the following ‘gateway constraints’ should apply. These reflect constraints that have been previously applied as part of the plan-making process. Sites which are substantially covered by one or more of these constraints will be discounted from the spatial strategy options and site selection process: Special Area of Conservation/Sites of Special Scientific Interest (SACs/SSSIs) Local Nature Reserves (LNR) Sites of Importance for Nature Conservation Ancient Woodland Geosite (Global Geopark) Flood Risk Zone 3 Scheduled Monuments (SM) Registered Parks and Gardens/Community Parks High Quality/High Value Open Space (for recreational purposes, as identified by the most recent Open Space Audit) Local Green Spaces (formally designated) Operational burial grounds There are constraints related to ownership which the Council has previously considered: Common Land – we would welcome views on whether this should be retained. Withdrawn sites (sites where the landowner and/or developer has explicitly stated they are no longer ‘available’ for development) - as the Council is inviting all sites to be submitted under a fresh Call for Sites process, this constraint is unlikely to remain relevant for the new Local Plan. Once the areas subject of ‘gateway constraints’ are excluded from the process, this leaves areas of currently undeveloped land which may be promoted for future development by landowners and/or developers. It is proposed that these areas would be the focus of further consideration under options for the spatial strategy and the site assessment process. Matters related to the overall sustainability of locations and sites would then also need to feed into the process for identifying reasonable spatial strategy options e.g., which are the most sustainable parts of the borough in terms of access to services and sustainable transport. Consideration will also be given to how options for development relate to the emerging Vision and measurable outcomes for the borough.

Key Steps

Key Considerations alongside the Key Steps

Step 1. Consider baseline position – land supply from the Dudley Local Plan) and the potential shortfall against updated development needs for the new Local Plan

Current housing land supply of 10,937 dwellings results in a substantial shortfall against the 2024 local housing needs (circa 12,000 dwelling shortfall over a 15-year plan period).
Employment land supply of 12.5ha results in a shortfall against the Dudley Local Plan needs- updated employment needs assessment to take place for the new Local Plan to establish updated position.
MHCLG draft guidance^[11] states that local authorities should assume that sites that are existing plan allocations or that have planning permission are suitable, available and achievable for development. These sites do not need to be assessed unless there is evidence to suggest that circumstances may have changed that would require further assessment.

National Planning Policy and guidance e.g., for calculating local housing needs and other development needs; for development densities; site selection; mix of development sites; steps for demonstrating ‘exceptional circumstances’.
Existing Local Plan housing and employment land supply and sites- review where necessary in line with national guidance.
The Local Plan Vision and measurable outcomes (how will the spatial options help to deliver local priorities and ambitions).
Local environmental considerations (the suitability of land for development).
Local land availability, viability and deliverability.

Step 2. Explore the potential for additional supply from the existing urban area and brownfield land

This could be undertaken by revisiting densities (seeking to optimise them further, wherever possible) and exploring any previously discounted sites, in accordance with national planning policy. The Council will need to consider any ‘gateway constraints’ to the development of sites within the existing urban area e.g., sites which are the subject of environmental designations (see Step 4 and related questions below).
Council to explore the potential to use emerging digital tools for land searches and site assessment could assist in identifying additional.

Step 3. Engage with neighbouring and other relevant local authorities (part of shared housing and economic market areas) to understand the wider housing and employment land supply and shortfall considerations and implications for Dudley.

Work for the West Midlands SDS is likely to inform this step (alongside any other relevant emerging SDSs) in terms of cross-boundary development needs and land supply.
Discussions to include whether any of Dudley’s development needs could be met outside of the borough (in accordance with national planning policy).
As part of the Dudley Local Plan contributions from other local authorities towards housing and employment land shortfalls in Dudley and the Black Country were considered. These contributions were however identified in a different context e.g., local housing and employment needs at the time and based on those other local authorities’ emerging local plans. Further discussions will be required to understand the latest position in respect of the contributions from other local authorities. It is noted that the scale of current contributions identified to date would not address the housing and employment land supply shortfalls identified in Dudley (set out at Step 1).

Step 4. Consider the potential for additional development sites outside the urban area to inform options for the spatial strategy

Following work under Steps 2 and 3, should a shortfall in meeting development needs still be identified then additional land supply options will be considered. This includes considering sites outside the existing urban area on greenfield land (and any brownfield land outside the urban area not already considered in Step 2). This includes land within the Green Belt. Potential for emerging digital tools for land searches and site assessment to assist in identifying additional sites
There are areas of undeveloped Green Belt and non-Green Belt land within the borough that are protected via other designations, which are likely to be considered ‘gateway constraints’ e.g., nationally designated environmental and heritage assets. This reduces the scope of options for the overarching spatial strategy and individual sites that can be considered for future development. The Council considers that the following ‘gateway constraints’ should apply. These reflect constraints that have been previously applied as part of the plan-making process. Sites which are substantially covered by one or more of these constraints will be discounted from the spatial strategy options and site selection process:
- Special Area of Conservation/Sites of Special Scientific Interest (SACs/SSSIs)
- Local Nature Reserves (LNR)
- Sites of Importance for Nature Conservation
- Ancient Woodland
- Geosite (Global Geopark)
- Flood Risk Zone 3
- Scheduled Monuments (SM)
- Registered Parks and Gardens/Community Parks
- High Quality/High Value Open Space (for recreational purposes, as identified by the most recent Open Space Audit)
- Local Green Spaces (formally designated)
- Operational burial grounds
There are constraints related to ownership which the Council has previously considered:
- Common Land – we would welcome views on whether this should be retained.
- Withdrawn sites (sites where the landowner and/or developer has explicitly stated they are no longer ‘available’ for development) - as the Council is inviting all sites to be submitted under a fresh Call for Sites process, this constraint is unlikely to remain relevant for the new Local Plan.
Once the areas subject of ‘gateway constraints’ are excluded from the process, this leaves areas of currently undeveloped land which may be promoted for future development by landowners and/or developers. It is proposed that these areas would be the focus of further consideration under options for the spatial strategy and the site assessment process.
Matters related to the overall sustainability of locations and sites would then also need to feed into the process for identifying reasonable spatial strategy options e.g., which are the most sustainable parts of the borough in terms of access to services and sustainable transport. Consideration will also be given to how options for development relate to the emerging Vision and measurable outcomes for the borough.

Figure 7: Map of Gateway Environmental Constraints

Map showing the environmental constraints within Dudley Borough. The borough boundary is outlined in black and a range of environmental and heritage designations are highlighted, including Scheduled Monuments, Conservation Areas, Special Areas of Conservation, Sites of Special Scientific Interest (SSSIs), Local Nature Reserves, Sites of Importance for Nature Conservation (SINCs), ancient woodland, flood zone 3, high-quality open space, registered parks, local green spaces, geological sites, and operational burial grounds. The map illustrates the distribution of environmental constraints across the borough and highlights areas that may require careful consideration when assessing development opportunities.

How will sites be assessed?

The new Local Plan will need to be informed by a site assessment process to determine which locations and sites represent the most appropriate and sustainable locations for future development.

The Council is currently reviewing its site assessment process for the new Dudley Borough Local Plan. This will draw upon the site assessment methodology used for the Dudley Local Plan but with any necessary amendments to account for national and local policy, guidance and context changes. Current government guidance on site assessment for the new plan-making process will be taken account of^[12]. We would welcome your views on the site assessment process as part of this consultation, including what updates or amendments you consider may be required to the site assessment methodology.

Question 18. Do you agree with the key steps for developing the spatial options outlined at this stage? Comment

Question 19. Do you agree with the ‘gateway constraints’ identified? Comment

Question 20. Do you agree that sites which are substantially affected by such constraints should be excluded from the spatial option and site selection process at this stage of plan-making? This would apply to the consideration of options and sites within and outside the existing urban area, and brownfield and greenfield land. Comment

Question 21. Do you have any comments on what updates or amendments may be required to the site assessment methodology used for the Dudley Local Plan? Comment

^[11] https://www.gov.uk/guidance/assessing-sites-for-local-plans-stage-2

^[12] MHCLG Guidance – Selecting sites for development

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