Part One: Spatial Strategy and Policies (Regulation 19)

9.19. 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.

9.20. The NPPF specifically states that for forecasting future trends:

9.21. 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 21ha 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.

9.22. 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 22.6ha. This source could yield further supply over the Plan period and will be monitored accordingly.

9.23. Current evidence states 50ha or 69% 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.

9.24. Details of the Black Country FEMA are shown in the above Figure 9.2 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, along 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.              

9.25. 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.

9.26. 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.              

9.27. 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.              

9.28. 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.

^[6] The figure to be exported by Dudley and the Black Country will be further reduced by the large and small site windfall allowances identified for the Black Country overall (78ha) but this is not disaggregated to individual local authority level at this time.