Dudley Borough Local Plan Scoping Consultation Document
11. Existing and new proposed evidence for the new Local Plan
What evidence base documents are required to inform the new Local Plan?
As part of the production of the Dudley Local Plan a wide range of evidence documents were prepared, some of which may have some continued relevance to the new Dudley Borough Local Plan. The Council is considering which existing evidence base documents may require a full or partial review.
As part of the new plan-making system, guidance around the process of evidence base production is emerging i.e., the potential for standardised evidence and reducing the range of evidence base documents required to help facilitate a 30-month plan production timetable. The Council is also exploring options for digital tools that can assist with the evidence base process e.g., in relation to site assessment.
The draft NPPF (2025) Policy PM8 ‘Evidence for plan making’ sets out some key principles in relation to evidence base production under the new plan-making system, including updating existing evidence, where appropriate, before preparing or commissioning wholly new evidence (which should be done only where necessary) and using standardised tools, methods or templates as provided by the Secretary of State.
As part of the production of the SDS, evidence base documents for the sub-region will also be prepared which may cover local matters sufficiently. The timing of this evidence would however need to align with the plan-making timetable for the new Dudley Borough Local Plan, and this is uncertain at this stage.
There are some existing sub-regional evidence base documents that the new Dudley Borough Local Plan can continue to have regard to until they are updated (as necessary) via the SDS. These are:
- West Midlands Strategic Employment Sites Study (2023).
- West Midlands Strategic Rail Freight Interchange Employment Issues Paper (2021).
- A refresh of the Strategic Growth Study (2019) for the GBBCHMA is currently underway.
- West Midlands Local Nature Recovery Strategy (2025)
The scope of the new proposed evidence is therefore subject to change as the plan progresses. Any changes arising from the new NPPF policies (expected to be published in summer 2026) will also need to be considered.
At this stage, we think that the Council may need to produce the evidence base documents set out below to inform the new Dudley Borough Local Plan. As noted above, the content and scope of the documents may differ from previous versions dependent upon emerging national policy and guidance, and any evidence produced at the sub-regional level for the SDS. The Dudley Local Plan is supported by an Infrastructure Delivery Plan which identifies what infrastructure is required to support the delivery of new developments, ensuring overall sustainable development. This cuts across a range of the topics set out below. An updated Infrastructure Delivery Plan will be prepared to support the new Dudley Borough Local Plan alongside the evidence base for the topics identified below.
For some topics it is likely that the Council will not need to commission its own new evidence base but can draw on the existing evidence of other service providers e.g., in relation to health and community facilities provision. We would welcome further input on the latest available evidence from partner organisations as part of this scoping consultation.
Strategic Environmental Assessment, Sustainability Appraisal and other technical assessments
The Council will legally[14] need to undertake a Strategic Environmental Assessment (SEA) for the Local Plan which assesses the options for proposed development against environmental objectives to identify the likely effects. Local Plans to date have also been required to be the subject of a Sustainability Appraisal (SA) which consider environmental objectives alongside social and economic ones. Government guidance on the SEA and SA process for the new plan making system is still emerging, however current guidance[15] states that by Gateway 1 of the plan making process the Council should have identified:
- relevant environmental protection objectives for the SEA at international, national or community level
- other relevant plans or programmes baseline information against which to assess the environmental impact of the plan, including the environmental characteristics of the area likely to be significantly affected, existing environmental problems and key receptors.
The SEA regime is also the subject of a review itself. The Government recently consulted (March 2026) on ‘Environmental Outcomes Reports: Roadmap to reform’. SEAs are due to be replaced with Environmental Outcomes Reports (EOR) in England. The ‘roadmap’ provides an overview of the
proposed changes, but the details are yet to be finalised ahead of the proposed implementation of new Regulations by the end of 2027.
The impact of this changing regime on the plan preparation and evidence base process will need to be considered as the Dudley Borough Local Plan progresses.
The Council has prepared a SEA Screening/Scoping Assessment to establish the need for and the framework for the SEA. This will be consulted on with the three consultation bodies - Natural England, the Environment Agency, and Historic England.
The Dudley Local Plan was also accompanied by a Habitat Regulations Assessment (to consider effects on the integrity of protected European wildlife sites) and an Equality Impact Assessment (to meet the Councils equality duty). We anticipate that these assessments will also be required for the new Local Plan (subject to any national legislative and/or policy changes).
Table 4: Reviewing Existing Evidence
|
Topic |
NPPF requirements (extant 2024 NPPF and draft 2025 NPPF) |
Existing Local Evidence base - Status and scope |
Full or partial review needed? Including potential SDS evidence. |
|---|---|---|---|
|
Housing |
NPPF (2024) paragraphs 62 and 63 Draft NPPF (2025) Policy HO1 and HO5 |
Strategic Housing Market Assessment (2024) Covers period 2024-2041 for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Full review to account for new plan period and updated NPPF. Potential for SDS to provide overarching evidence base for sub-region. |
|
NPPF (2024) paragraphs 20 and 72 Draft NPPF (2025) Policy PM9 and Policy HO3 |
Strategic Housing Land Availability Assessment (updated annually) |
This will be updated at least annually to inform the Local Plan preparation. To be informed by the latest Call for Sites. |
|
|
Planning Policy for Traveller Sites (2024) Policy A and Policy B NPPF (2024) paragraph 63 Draft NPPF (2025) Policy HO1 |
Gypsy and Traveller and Travelling Showpeople Needs Assessment (2022) Covers period 2021-2041 for Dudley Local Plan (2026). Produced in accordance with 2021 Planning Policy for Traveller Sites. |
Full review to account for new plan period and updated NPPF (which proposes to bring in the current Planning Policy for Traveller Sites, as amended). Potential for SDS to provide overarching evidence base for sub-region. |
|
|
Employment |
NPPF (2024) paragraphs 20 and 86 Draft NPPF (2025) Policy PM9 and Policy E1 |
Employment Land Needs Assessment (2024) Covers period 2020-2042 for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Full review to account for new plan period and updated NPPF. Potential for SDS to provide overarching evidence base for sub-region. |
|
Employment Land Availability |
Updated annually via Authority Monitoring Report. To be informed by latest Call for Sites and potential updated landowner engagement exercises. |
||
|
Black Country Employment Areas Review (2021) Produced for Dudley Local Plan (2026). |
Partial review to account for any known changes to existing employment areas and their quality within the borough. |
||
|
Centres (retail, leisure, office and other main town centre commercial developments) |
NPPF (2024) paragraphs 20 and 90 Draft NPPF (2025) Policy PM9 and Policy TC1 |
Black Country Centres Study (latest update in 2024) Covers period up to 2041 for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Full review to account for new plan period and updated NPPF (overall growth needs). |
|
Dudley Borough Strategic, Town, District and Local Centre Healthchecks (updated annually) |
This will be updated annually to inform the Local Plan preparation. |
||
|
Land availability for any main town centre uses |
To be informed by latest Call for Sites and needs for main town centre uses. |
||
|
Promoting healthy and safe communities |
NPPF (2024) paragraph 104 Draft NPPF (2025) Policy HC1 |
Playing Pitch and Outdoor Sports Assessment and Strategy (2022) Covers period up to 2041 for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Full review to account for new plan period and updated NPPF (overall growth needs). |
|
Open Space Assessment (2019) Produced for former Black Country Plan and used to inform the Dudley Local Plan (2026). Produced in accordance with 2019 NPPF. |
Full review is currently underway. |
||
|
Sustainable Transport |
NPPF (2024) paragraph 109 Draft NPPF (2025) Policy TR1 |
Black Country Transport Modelling Report (2023 and 2024) Produced for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Full review to account for new plan period and updated NPPF (overall growth needs). |
|
Green Belt |
NPPF (2024) paragraph 148 Draft NPPF (2025) Policy GB2 |
Black Country Green Belt Assessment (2019) Produced for former Black Country Local Plan. Produced in accordance with 2019 NPPF. |
New borough-wide study is currently underway to reflect updated NPPF. Potential for SDS to provide overarching evidence base for sub-region (strategic level assessment only). |
|
Climate change, Flood Risk and Water (note there are also crossovers with the natural environment and sustainable transport evidence base for this topic) |
NPPF (2024) paragraph 171 Draft NPPF (2025) Policy CC1 and Policy F1 |
Strategic Flood Risk Assessment – Level 1 and 2 (2025) Produced for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. New flood risk data has been since published. |
Potential partial review as not tied to plan period or overall growth requirements - sense check of implications of new flood risk data. May require full review dependent upon sense check and to accord with updated NPPF. Any new development sites will also need to be assessed. |
|
Draft NPPF (2025) Policy PM13, Policy CC1 and Policy W1 |
Water Cycle Study (Phase 1- 2020 and Phase 2- 2024) Produced for former Black Country Plan and used to inform the Dudley Local Plan (2026). Produced in accordance with 2019 and 2023 NPPF. |
Full review to account for new plan period and updated NPPF (overall growth needs). |
|
|
Natural environment |
NPPF (2024) paragraphs 187, 188 and 192 Draft NPPF (2025) Policy CC1 and N1 |
Internationally and nationally designed nature conservation sites such as SACs, SPAs, Ramsar sites, SSSIs and NNRs. Local Site Assessments completed for each of the adopted local wildlife site designations (SINC/SLINC). West Midlands Local Nature Recovery Strategy (LNRS). Published in 2025. |
Full review to ensure that new designations have been accounted for. Green Infrastructure Evidence may be required |
|
NPPF (2024) paragraphs 135c, 151, 187 Draft NPPF (2025) Policy N1 |
Landscape Sensitivity Assessment (2019) (Note this also crosses over into Historic Environment matters). Produced for former Black Country Local Plan. Produced in accordance with 2019 NPPF. |
Full review is currently underway. |
|
|
Historic environment |
NPPF (2024) paragraphs 135c, 151, 187, 203, 205 and 208 Draft NPPF (2025) Policies HE1 -HE3 |
Black Country Historic Landscape Characterisation Study (2019) and characterisation studies for Brierley Hill, Dudley, Stourbridge and Halesowen. Produced for former Black Country Plan and used to inform the Dudley Local Plan (2026). |
Considered to be up to date. |
|
Dudley Local Plan Heritage Impact Assessment (2025) Produced for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Partial update to reflect any new site allocations in the Dudley Local Plan and to reflect any changes in NPPF/guidance for carry forward allocations. Any updates to existing documents related to Conservation Areas (Appraisals and Management Plans) and the Historic Environment Record will need to be taken account of. |
||
|
Waste and Minerals |
National Planning Policy for Waste (NPPW, 2014) NPPF (2024) paragraph 223 Draft NPPF (2025) Policy M1 and Policy M2 |
Dudley Waste and Minerals Studies (2023) Produced for Dudley Local Plan (2026). Produced in accordance with 2014 NPPW and 2023 NPPF. New Environment Agency Waste Data Interrogator (EA WDI) data has since been published. |
Full review of waste study to account for new plan period and updated NPPF (overall growth needs). Updated waste data to be accounted for (latest EA WDI). Potential partial review of mineral study as no changes to position in terms of primary aggregates sites and supply (i.e., no workable minerals and/or potential quarries). Updated waste data to be accounted for in relation to secondary and recycled aggregates (latest EA WDI). Review to account for draft NPPF (2025) updates to reference critical and growth minerals. |
|
Viability |
NPPF (2024) paragraphs 59, 72 and 129 Draft NPPF (2025) Policy PM9 and Policy PM12 |
Dudley Local Plan Viability Assessment (2024) Produced for Dudley Local Plan (2026). Produced in accordance with 2023 NPPF. |
Potential partial review as not tied to plan period or overall growth requirements - sense check of viability context and assumptions required. May however require full review dependent upon sense check and to accord with updated NPPF, including any new site typologies based on site allocations. |
|
Infrastructure and Energy |
Draft NPPF (2025) Policy W1 and Policy W2 |
Black Country Utilities Study and Dudley Local Plan Infrastructure Delivery Plan. |
Partial review is required. |
|
Design and Density |
Draft NPPF (2025) Policy L1 and Policy DP1 |
Informed by Historic and Natural Environment evidence and sustainable transport evidence. |
|
|
Clean and safe places |
Draft NPPF (2025) Policy P1 |
Informed by existing evidence e.g., on former landfills etc. |
Question 22. Do you have any comments on the potential evidence base at this stage? Comment
Question 23. Are you aware of specific up to date evidence base documents which can or should be used to inform the new Dudley Borough Local Plan from your own or other organisations? Comment
Question 24. Is there any other evidence you feel we may need to inform our new Local Plan that would be relevant and proportionate? Comment
[14] As per the Environmental Assessment of Plans and Programmes Regulations 2004
[15] MHCLG guidance- Getting ready to prepare a new plan
