Part One: Spatial Strategy and Policies (Regulation 19)
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: instead 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:
- 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.
- 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.
- 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.
- 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.
- 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.
- the Plan also needs to ensure that the 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).
- it is imperative to protect the existing supply of land to meet future needs that will arise from a high growth-driven economy.
- 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:
- to facilitate the growth and diversification of the economy, the Plan allocates land for new development within the Dudley Borough, to accommodate jobs and output growth (Policy DLP18).
- 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).
- 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).
- to recognise that some sites will become unsuitable for continued employment uses and to facilitate their redevelopment to alternative uses including housing (Policy DLP21).
- 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 22.34ha 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.
9.12. It should be noted that Black Country EDNA is being updated to reflect the Plan period for the Wolverhampton Local Plan to 2042, and to ensure that the use of the economic modelling has regard to more recent census data and the most recent post covid economic data available.
9.13. The issue of strategic employment delivery across the wider West Midlands region has been explored through the West Midlands Strategic Employment Sites Study (WMSESS) 2023 (published September 2024). The WMSESS was commissioned by Dudley MBC on behalf of the West Midlands Study Area Local Planning Authorities and the West Midlands Combined Authority.
9.14. The purpose of the WMSESS was to provide an updated position on currently committed strategic sites and identify the need for large scale strategic logistics and manufacturing sites for the period up to 2045, whilst engaging with the private sector to gauge market demand and modern industry requirements.
9.15. The WMSESS concluded that there was a considerable demand for strategic employment site opportunities across the region, and identified a number of broad opportunity areas which were considered to be appropriate growth locations to meet need arising from 2030's to 2045.
9.16. The study identified 14 road/rail opportunity areas, including opportunity areas around M6/M54 in South Staffordshire and M42/M5/A435 in Redditch and Bromsgrove.
9.17. The recommendations from the Study will be used to inform Local Plan preparation, including the early review of relevant Plans.
9.18. Based on the Study's findings, it is not considered feasible for a strategic employment site (>25ha) to be allocated within the Dudley Borough. However, Dudley, along with other local authorities in the Black Country FEMA, will continue to engage with those neighbouring authorities who share a strong/moderate or evidence relationship with the FEMA to identify opportunities to bring forward strategic employment sites.
Figure 9.1 Spatial Strategy Plan: Employment