Part One: Spatial Strategy and Policies (Regulation 19)

Ended on the 29 November 2024

3. Context of the Local Plan

National Context

National Requirements for Plan-making

3.1. The Draft DLP has been prepared in accordance with the National Planning Policy Framework (NPPF 2023) and its associated Planning Practice Guidance (PPGs) and best practice advice notes produced by Historic England. The NPPF sets out the national approach to planning in England and emphasises the role of sustainability in guiding plans and policies, setting out three dimensions to sustainable development, these being economic, social and environmental.

3.2. National policy requires that all plans set out a vision and a framework for future development and seek to address the strategic priorities for the area. The strategic policies for an area should include policies and site allocations to address key issues such as:

  • an overall strategy for growth
  • housing (including affordable housing)
  • commercial development
  • retail and leisure
  • infrastructure
  • community facilities
  • climate change
  • conservation and enhancement of the natural and built environment.

3.3. Plans should be clear in identifying strategic policies. They should form a starting point for local non-strategic policies which can include more detailed development management policies. Strategic policies should include a clear spatial strategy for bringing forward enough land to address housing needs over the plan period and be underpinned by relevant and up to date evidence. It is now a legal requirement to have completed a review of the Local Plan within 5 years of its adoption to take account of changing circumstances affecting the area.

3.4. The NPPF sets out that Local Plans should be prepared in line with procedural and legal requirements and will be assessed on whether they are considered 'sound'. Plans are considered sound if they are: positively prepared, justified, effective, and consistent with national policy.

Sub-regional and local policy context

3.5. Dudley is a constituent member of the West Midlands Combined Authority (WMCA) which was established in 2016. The WMCA overarching objective is to build 'a better connected, more prosperous, fairer, greener and healthier West Midlands'. To deliver this objective, the WMCA have developed a number of strategies and associated programmes relevant to the preparation of the DLP. These are summarised below.

3.6. The WMCA Strategic Economic Plan (SEP) was adopted in 2016 and sets out the vision, objectives, strategy and actions needed to improve the quality of life for everyone who lives and works in the West Midlands. While this strategy pre-dates Britain leaving the European Union, the Covid-19 recession, and ongoing shifting economic turbulence, it outlines a number of high-level challenges facing the West Midlands which remain relevant. These include:

  • Bringing forward land for housing and employment
  • Accelerating the rate of house building to match aspirations for growth

3.7. WMCA produced the West Midlands Local Industrial Strategy (LIS) which was published in May 2019. The LIS demonstrates how the West Midlands is forging its future and building an inclusive and balanced economy. Together with the supporting documents published locally, it shows the West Midlands is taking action to continue growth in productivity and earning power for all.

3.8. In July 2022, the WMCA published their Plan for Growth which captures the key features of the West Midlands economy. The Plan for Growth pinpoints clusters where the West Midlands has comparative advantage and businesses are confident to invest. Working in conjunction with local authorities and universities as local anchor institutions, the WMCA will deliver conditions for growth through:

  • New powers over economic development
  • Transport investment
  • Housing and land investment
  • Pioneering new approaches to regeneration
  • Developing skills
  • Working with investors
  • Committing to net zero by 2041

3.9. WMCA's strategies have formed the basis for a range of investment programmes supported by Government funding packages. One of the priorities for this funding is the delivery of projects which provide land for new homes and employment. WMCA has led the way nationally in the delivery of brownfield land, including sites in Dudley, and moving forward, over the lifetime of the DLP, this activity will continue, providing valuable support to unlock constrained sites and deliver critical infrastructure. The focus of this future work includes supporting projects in town centres to enable them to thrive again, innovative approaches to the delivery of sustainable homes, zero carbon homes and the delivery of land to support business needs.

3.10. Dudley Council will continue to work closely with the WMCA to drive forward investment in housing, regeneration, transport and employment to deliver a better connected, more prosperous, fairer, greener and healthier West Midlands.

West Midlands Local Transport Plan

3.11. The West Midlands Local Transport Plan (LTP) 2011-2026 Movement for Growth sets out clear objectives for dealing with transport issues, problems and challenges in the wider region and within the Black Country sub-region. It draws on a number of national, regional and local planning and transportation policy documents to ensure that the strategy guides the delivery of wider objectives. A new West Midlands LTP is being developed to replace Movement for Growth and will set out overall aims, vision and approaches to guide the development and delivery of transport policies until the end of 2041. The emerging strategy seeks to: sustain economic success; create a fairer society; support local communities and places; become more active; and tackle the climate emergency.

Sub-regional Context

3.12. The Black Country – made up of the local authorities of Dudley, Sandwell, Walsall and Wolverhampton - forms a distinctive sub-region on the western side of the West Midlands conurbation. It shares an eastern boundary with the City of Birmingham and to the north, west and south it is bounded by districts in Staffordshire, Shropshire and Worcestershire, it is in relative proximity to the local authority areas of South Staffordshire, Wyre Forest, Shropshire and Bromsgrove. The Black Country sub region has a unique economic history, settlement form and topography and is very much shaped by its industrial past.

3.13. The four Black Country Authorities (BCAs) have a shared set of social, economic, and environmental issues and challenges, and have a long history of successful joint working most notably through the Black Country Local Enterprise Partnership (LEP). The LEP was established in 2011 with an overarching objective of creating jobs and building a strong economy by tackling barriers to sustainable growth, securing and delivering a total of £2.4bn of funding. The LEP has now been disbanded, along with others throughout England, with key functions transferred to other organisations including WMCA.

3.14. The Council's current adopted local plans (Black Country Core Strategy and Dudley Borough Development Strategy) and the DLP set out the Council's regeneration aspirations for the borough and provide a basis for the public and private sector investment decisions, including the devolved housing and land funds agreed with Government, the Towns Fund, levelling up funding and other regeneration led funds.

The Local Context

"Forging a Future for All"

3.15. The DLP, once adopted, will help to deliver the Council's priorities across a range of policy areas through addressing climate change, supporting sustainable development and appropriate land use.

3.16. Under current legislation, local plans are required to identify a clear vision setting out what the authority wants to achieve through its approach to land use and development and setting out the strategic priorities to achieve this.

3.17. The Vision set out in the Draft DLP has been guided by the Council's adopted corporate strategies. "Forging a Future for All" is the borough's Vision to 2030 which was developed with extensive engagement with stakeholders. The Vision sets out seven aspirations of what it would like the borough of Dudley to be:

  1. An affordable and attractive place to live with a green network of high-quality parks, waterways and nature reserves that are valued by local people and visitors
  2. A place where everybody has the education and skills they need, and where outstanding local schools, colleges and universities secure excellent results for their learners
  3. A place of healthy, resilient, safe communities where people have high aspirations and the ability to shape their own future
  4. Better connected with high quality and affordable transport, combining road, tram, rail, and new cycling and walking infrastructure
  5. Renowned as home to a host of innovative and prosperous businesses, operating in high quality locations with space to grow, sustainable energy supplies and investing in their workforce
  6. A place to visit and enjoy that drives opportunity, contributing to its ambitious future while celebrating its pioneering past
  7. Full of vibrant towns and local centres, offering a new mix of leisure, faith, cultural, residential and shopping uses.

3.18. This Vision has been used to inform the Vision for the DLP.

Dudley Council Plan

3.19. The Council's previous Council Plan that was expected to run from 2002 to 2025 was suspended in March 2024 and replaced with a new one-year plan for 2024-25. This Plan has been produced as part of the Council's Fit for the Future programme and reflects the Council's focus on becoming a financially sustainable organisation.

3.20. The interim Council Plan focuses on priorities and projects that will support the overall sustainability of the Council and the services we deliver to our residents and support the delivery of the Council's improvement and sustainability programme.

3.21. The new plan has 5 key priority areas which are supported by additional narrative on the outcomes that the Council aims to achieve including the need to improve its governance, decision making, leadership and financial resilience whilst maintaining the delivery of core services to our residents and communities:

  • Financial sustainability, efficiency and providing best value
  • Governance and control
  • Leadership and culture
  • Delivering for our customers, residents and communities
  • Supporting businesses and the local economy

Dudley Health and Wellbeing Strategy 2023-2028

3.22. The Health and Wellbeing Board's vision for Dudley to 2028 is that the borough will be a place where everyone lives longer, safer and healthier lives. The Strategy will focus its resources and energy on 3 goals which will have the biggest impacts on people's health and wellbeing:

  1. Children are ready for school
  2. Fewer people die from circulatory disease
  3. More women are screened for breast cancer

3.23. Across all of these 3 goals the Board will embed an approach to reduce health inequalities – to close the gap in health and wellbeing for the most disadvantaged families and communities and ensure a focus on the wider determinants of health such as income and employment, unleash the potential of our communities, and deliver services furthest and fastest to those who need them most.

Dudley Climate Change Action Plan

3.24. The Dudley Climate Change Action Plan is the Council's commitment to action to address climate change following its declaration of a Climate Emergency in July 2020. The Council pledged to make all council activities net carbon zero by 2030 and has also pledged to work with partners to make Dudley a net carbon zero borough by 2041.

3.25. Achieving these targets will require the Council to embed low carbon practices within its planning policy, land allocations, development and regeneration, and to work closely with its partners to maximise the use of low carbon solutions.

Dudley Borough Economic Regeneration Strategy 2024

3.26. The Council has produced an Economic Regeneration Strategy to shape a more prosperous, more equitable and more sustainable economy in which businesses and communities thrive.

3.27. The strategy outlines the Council's proposed approach to economic development and regeneration and how the Council will work alongside partners to support the local economy to grow. The strategy is based upon four key themes of: unlocking enterprise and innovation, investing in people and building skills for tomorrow, creating a vibrant creative and cultural environment, and supporting the visitor economy and reinventing town centres across the borough. These four themes are underpinned with a cross-cutting priority of maximising the impact of Midland Metro and driving investment in future connectivity.

3.28. The strategy will inform the main focus of the Council's regeneration and enterprise work and will seek to achieve the following outcomes for the Borough:

  • new businesses are formed, and existing businesses grow – including in new sectors
  • inward investors choose to locate in the borough
  • local people develop new skills and can 'pivot' as new opportunities come to the area
  • town centres are vibrant and sustainable, and attractive both to local people and visitors
  • the quality of the natural and built environment (including heritage assets) are recognised at the heart of the visitor economy and more generally
  • communities and businesses are connected by a high-quality transport infrastructure across the borough
  • significant progress is being made towards net zero carbon
  • everyone can reach their potential

3.29. Delivering these aims will require a positive spatial planning framework

Cross boundary issues and Duty to Cooperate

3.30. Under the Localism Act 2011, Local Planning Authorities have a legal duty to co-operate (DtC) with neighbouring authorities and other prescribed bodies on strategic matters that cross administrative boundaries. Strategic matters can include housing, employment, infrastructure, and the green belt. The Council has been working collaboratively with neighbouring authorities and prescribed bodies on cross boundary issues and infrastructure requirements for a number of years (including the period before the end of the Black Country Plan) and will continue to do so as the DLP progresses through to adoption stage.

3.31. The NPPF presumption in favour of sustainable development makes it explicit that authorities should plan for their own objectively assessed needs for housing and other development, as well as any needs that cannot be met in neighbouring areas. Agreement through Statements of Common Ground (SoCG) are now a necessity and will document the cross-boundary matters that need to be addressed and what progress has been made in dealing with them.

3.32. The Council's Duty to Co-operate Statement prepared to support the Publication stage of the DLP demonstrates how Dudley MBC has fulfilled its duty through the preparation of the DLP and how the relevant bodies and DtC engagement, as referred to in the Localism Act, have helped to shape the emerging Plan.

3.33. Draft Statements of Common Ground have been produced to support the Publication Plan stage of the DLP with relevant authorities and bodies on key Duty to Co-operate issues. These Statements of Common Ground will be formalised following the consultation on the Regulation 19 Publication Plan and prior to the submission of the Plan to the Secretary of State.

3.34. Duty to Co-operate discussions have been ongoing with neighbouring authorities and potential contributions to the Black Country and the Greater Birmingham and Black Country Housing Market Area (GBBC HMA) have been offered through several Local Plans, however these are still to adopted and the offers may change.

3.35. As of August 2024, the following contributions have been offered towards the unmet housing and employment land needs of the Black Country Authorities and Birmingham City Council. These contributions are subject to each local authority testing this through their local plan review and/or local plan examinations. These contributions will go some way in reducing the shortfalls identified for Dudley. However, it should be noted that contributions made to the Black Country Authorities, Greater Birmingham/Black Country HMA or Black Country FEMA will need to be apportioned to each authority via agreement and Statements of Common Ground. The tables below set out the potential contributions to date and will be updated as necessary and when contributions have been confirmed.

Housing

Local Authority

Potential Contribution

Detail

Shropshire Council

1,500

Contribution to the Black Country LAs.

Cannock Chase Council

500

Contribution to the Birmingham/Black Country HMA

South Staffordshire Council

640

Contribution to the Birmingham/Black Country HMA

Telford & Wrekin Council

1,650

Contribution to the Black Country LAs

Employment

Local Authority

Potential Contribution

Status

West Midlands Interchange (South Staffs)

67ha

14ha apportioned to Dudley's employment land requirements.

Shropshire

30ha

Contribution to the Black Country FEMA

South Staffordshire

45.2ha

Contribution to the Black Country FEMA

Evidence base

3.36. The preparation of a Local Plan must be based on a wide variety of up to date and robust evidence, providing technical information specific to Dudley or the sub-region.

3.37. A considerable body of evidence, background documents and data covering a range of planning issues supported the preparation of the BCP and the DLP. These are available on the Council's website: https://www.dudley.gov.uk/localplan. After each policy in this document there is a bullet point list of the key evidence that has helped shape that policy.

3.38. The evidence base to support the preparation of the DLP has been updated where necessary alongside each stage of the plan making process.

Sustainability Appraisal

3.39. All local plans must contribute to achieving sustainable development, aiming to achieve a better quality of life for all, both now and for future generations. A Sustainability Appraisal (SA) is a statutory requirement, which ensures that the environmental, social and economic effects of a plan and reasonable alternatives to the plan are being considered. The SA assesses the sustainability of the strategic approach, proposed allocations and reasonable alternatives, and the content of the policies contained in a plan.

3.40. The Local Plan must contribute to achieving sustainable development, aiming to achieve a better quality of life for all, both now and for future generations. A Sustainability Appraisal (SA) is a statutory requirement which ensures that the environmental, social and economic effects of a plan and reasonable alternatives to a plan are being considered A separate SA was prepared to appraise proposals at each stage of Local Plan preparation and was subject to consultation. The SA assesses the sustainability of the strategic approach, proposed allocations and reasonable alternatives, and the content of the policies contained in the plan. The SA findings have been used to help refine policy choices and site options through to the final proposals set out in the Local Plan. Copies of the SA can be viewed on the Council's website: https://www.dudley.gov.uk/localplan.

Habitats Regulation Assessment (HRA)

3.41. The Habitats Directive establishes an ecological network of protected European Sites (Natura 2000 Network) and requires consideration of whether or not an Appropriate Assessment needs to be undertaken during the preparation of a Local Plan. The purpose is to assess what effects, if any, the plan might have on protected European sites.

3.42. A Habitats Regulations Assessment (HRA) has be undertaken as required by Regulation 61 of the Conservation of Habitats and Species Regulations 2010 (as amended) in order to see whether the plan could have the potential to result in likely significant effects upon protected European sites and sites of international importance for nature conservation.

3.43. Further information on the HRA process can be found in the HRA documentation and on our website: https://www.dudley.gov.uk/localplan.

Equality Impact Assessment (EqIA)

3.44. The Council has a duty under the Equality Act 2010 to carry out an Equality Impact Assessment (EqIA) for all plans, strategies and proposals in order to eliminate unlawful discrimination, promote equality of opportunity and promote good relations between people of different equality groups. The protected characteristic groups include age, disability, gender reassignment, religion/belief, pregnancy and maternity, sexual orientation and sex; all of which are considered to be at particular risk of discrimination.

3.45. The Council has published an EqIA to accompany this Local Plan. The EqIA has been updated at each stage of the Plan process.

Issues and Challenges for Dudley Local Plan

3.46. Dudley Council, alongside other Black Country Authorities, were involved in the preparation of a replacement Plan to the Black Country Core Strategy. Work on the Black Country Plan (BCP) commenced in 2017 with an Issues and Options consultation and progressed to a Draft Plan (Regulation 18) consultation in Summer 2021. Work on the production of the joint BCP officially ceased in October 2022.

3.47. The preparation of the DLP commenced in November 2022. Given the work that had already been undertaken on the BCP, both in terms of evidence gathering and policy writing, and acknowledging that it had been through two public consultations (including an Issues and Options consultation in 2017 and Draft Plan Regulation 18 consultation in 2021), the Council took the decision that there was merit in retaining and adapting some of the policies to be taken forward in the DLP. In addition, the Council consulted on an Issues and Options consultation for the review of the Brierley Hill AAP in 2022.

3.48. On this basis, the Council produced a 'hybrid local plan' which acknowledges the issues and the responses made during the draft BCP public consultations and the Brierley Hill AAP Issues and Options consultation as well as the issues informed by our evidence base.

3.49. The DLP includes policies previously seen and consulted on in the BCP and has adapted these policies to make them more specific to our borough. It is likely that other Black Country councils will be doing the same, including similar or shared policies on certain issues such as pollution, transport, nature conservation networks and other more strategic aspects of land use. This will make it much easier to ensure such matters are dealt with in a more effective way across boundaries.

Previous Consultations on the Dudley Local Plan

Black Country Plan Issues and Options and Draft Plan (Regulation 18) and Brierley Hill AAP Issues and Options

3.50. The consultation of the Draft DLP (Regulation 18) responded to the issues raised by the public and others during the public consultation on the draft BCP (held during Summer 2021) and Brierley Hill AAP Issues and Options consultation from January – February 2022.

3.51. Stakeholder engagement throughout the BCP plan preparation and the Brierley Hill AAP Issues and Options consultation confirmed a number of issues and challenges in Dudley that should be addressed by the new DLP. Alongside this, the technical evidence based produced to inform the Plan has identified some of the key issues to be considered and addressed as part of the plan making process.

3.52. A summary of the key issues raised in both consultation is set out in the Draft Plan Consultation Statement October 2023.

Draft Dudley Local Plan (Regulation 18)

3.53. The consultation on the Draft DLP (Regulation 18) held between November to December 2023 was the first stage of public consultation on the Draft DLP. This Draft Plan built upon previous consultations as discussed in para 2.49 and 2.50 taking on board all representations received. This consultation set out the proposed site allocations to meet the preferred strategy, strategic policies and Development Management policies and asked for views on these.

3.54. A summary of the key issues /representations received and our response to these is set out in the Draft Dudley Local Plan (Regulation 18) Consultation Statement 2024.

3.55. The representations received on the Plan consultations, alongside our existing and updated evidence base throughout plan preparation process, has confirmed a number of issues and challenges in Dudley that should be addressed by the new Local Plan and has helped to shape key plan policies and directions. These issues and challenges are summarised briefly below in Tables 3.2-3.4.

Publication Plan

3.56. This stage of Local Plan consultation is known as a Regulation 19 consultation and representations at this stage must focus on whether the plan meets the tests of soundness set out in the NPPF. This is the plan that will be submitted for independent examination.

Table 3.2 Homes and Communities – Issues and Challenges

Issues

DLP proposed policy framework to address issues

Evidence

Having a land supply to meet the housing needs for the borough including potential for assisting/or seeking assistance from neighbouring authorities via DtC.

Improving the lives of residents and meeting the needs of future generations through the supply of land for new development to provide to new homes. A growing and changing population compounds local housing need pressures. The DLP has a role in addressing this issue by providing a range and choice of accommodation, house types and tenures to improve and diversify the housing offer, and to meet the needs of current and future residents.

Making efficient use of land to address the needs of the borough.

Needing to work with neighbouring authorities to address unmet development needs.

  • Urban Capacity Review (UCR) 2024
  • Strategic Housing Land Availability Assessment (SHLAA) 2024
  • Accessibility modelling 2020
  • Dudley Housing Market Assessment (HMA) 2024

Meeting the borough's gypsy and traveller and travelling show people's needs.

Improving the lives of residents and meeting the needs of future generations through the supply of land for new development to provide accommodation for Gypsy and Traveller and Travelling Showpeople. Need to provide additional Gypsy and Traveller and Travelling Showpeople pitch and plot provision through working with neighbouring authorities to address unmet development needs.

  • Urban Capacity Review (UCR) 2024
  • Strategic Housing Land Availability Assessment (SHLAA) 2024
  • Accessibility modelling 2020
  • Black Country GTAA 2022 and updated Dudley figures in 2023

Location of development and distribution of growth

A number of options on the scale and location for growth has been taken into consideration in the DLP options and spatial strategy and the selected range of preferred allocations.

  • UCR 2024
  • SHLAA 2024
  • EDNA October 2023
  • Black Country Economic Review(BEAR) 2021
  • Sustainability Appraisal 2024

Location of development and distribution of growth

Prioritising the allocation of brownfield land. Reusing suitable brownfield land for new development can provide an effective use of land and reduces the need for development on previously undeveloped greenfield sites. National policy places great emphasis on the efficient use of urban land - it is a key component of sustainable development and can help to tackle the climate emergency. Identifying the potential of existing urban areas to accommodate additional residential development is an important component of the growth strategy for Dudley borough and the DLP.

  • UCR 2024
  • SHLAA 2024
  • EDNA October 2023
  • BEAR 2021
  • Sustainability Appraisal 2024
  • Dudley Borough Economic Regeneration Strategy (2024)

Delivering a variety of homes, to meet the needs of all groups of the community and delivering affordable housing

Building the right homes in the right places for people at all levels of income. The DLP needs to allow for new homes that meet the diverse needs of all our residents, including affordable, old persons, specialist and self and custom build housing, along with the accommodation needs of gypsy and traveller and travelling showpeople communities.

  • Dudley HMA 2024
  • Accessibility modelling 2020
  • Dudley Delivery and Viability Study 2023 and 2024

Viability and delivery of identified sites for growth

The development strategy for the DLP needs to be both deliverable and viable, which means that there is a sufficient level of confidence that the sites and locations identified for development are able to come forward and deliver all that is required of them in terms of necessary infrastructure provision. The Plan will make provision for a policy framework that takes account of market conditions and produce an Infrastructure Delivery Strategy to ensure that the preferred development strategy is both deliverable and viable.

  • Dudley Delivery and Viability Study 2023 and 2024
  • Infrastructure Delivery Plan 2024
  • Dudley Borough Economic Regeneration Strategy (2024)
  • Dudley Borough Place Based Strategy (2024)

Delivering homes of a high-quality and design that reflect the character and distinctiveness of the borough

Design is an overarching concept which interacts directly or indirectly with all other aspects of the plan. Strategic design policies in the DLP aim to form the foundations on which to build future detail and ensure that development is located and designed to create places for all residents in future.

  • Black Country Historic Landscape Characterisation (HLC) 2019
  • Emerging Design Code- Lye and Stour Valley 2023/2024

Ensuring access to local services and supporting infrastructure

Growth is underpinned by sufficient infrastructure - open spaces, community and health facilities and digital networks. Both Physical and social infrastructure will be required 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 infrastructure solutions

  • Delivery and Viability Study 2023 and 2024
  • Liaison with health and education providers
  • Utilities Infrastructure Capacity Study for the Black Country 2019
  • Dudley Waste Study 2023
  • Infrastructure Delivery Plan 2024
  • Dudley Borough Economic Regeneration Strategy (2024)

Balancing growth across communities by ensuring that local services and facilities continue to thrive.

Growth is underpinned by sufficient infrastructure - open spaces, community and health facilities and digital networks. The sufficient provision of infrastructure is an essential element of creating sustainable communities, centred around that which delivers social, environmental and economic objectives. Working with infrastructure providers to review of infrastructure needs will enable measures can be put in place to ensure that new development is supported by appropriate and timely infrastructure.

  • Delivery and Viability Study 2023 and 2024
  • Liaison with health and education providers
  • Utilities Infrastructure Capacity Study for the Black Country 2019
  • Infrastructure Delivery Plan 2024

Addressing the health and wellbeing of residents and inequalities across the borough

Stark inequalities continue to exist in the conditions in which people are born and live in the borough, which in turn has an adverse effect on people's health and wellbeing. The strategy and policies in the DLP recognise the important role that spatial planning has in the creation of healthy, safe, and inclusive communities and that the places that we live in have a fundamental impact on health. The DLP has a role in addressing existing health and wellbeing issues in by providing a built and natural environment that protects health and wellbeing through: supporting the making of healthier choices; minimising pollution (air, noise and other forms); providing healthy homes; providing a range of employment opportunities; supporting and facilitating investment in health infrastructure; reducing the negative health effects of climate change; and providing streets safe for active, low emission travel for all.

  • Dudley Health and Wellbeing Strategy 2023-2028

Infrastructure needed to support new growth

The sufficient provision of infrastructure is an essential element of creating sustainable communities, centred around that which delivers social, environmental and economic objectives. Working with infrastructure providers to review of infrastructure needs will enable measures can be put in place to ensure that new development is supported by appropriate and timely infrastructure.

  • Black Country Transport modelling 2024
  • Liaison with health and education providers
  • Utilities Infrastructure Capacity Study for the Black Country 2019
  • Dudley Waste Study 2023
  • Dudley Water Cycle Study 2024
  • Dudley Strategic Flood Risk Assessment (SFRA) 2024

Supporting struggling centres and high street vacancies.

Centres play an important part in supporting economic growth and encouraging investment. It is important to maintain the shopping function of town centres that enhance their respective roles within the local Retail Hierarchy whilst also revitalising our centres through diversification, repurposing and investment. The DLP will need to address the health and the vitality and viability of the borough's centres. The DLP should provide a flexible policy framework to allow centres to serve the future growth identified (particularly residential led housing), diversify and provide policies to defend against proposals that could undermine centres, such as out-of-centre developments.

  • Black Country Centres Study update 2024
  • Annual Centres Health Check 2024
  • Dudley Borough Economic Regeneration Strategy (2024)
  • Dudley Borough Place Based Strategy (2024)

Need for improved transport links to connect people and businesses.

Better Connectivity: public transport, walking routes, cycle paths. Transport policies have been reviewed and updated to place a stronger focus upon active travel and sustainable transport plus potential new strategic investment opportunities.

West Midlands Strategic Transport Plan - Movement for Growth (TfWM 2016)/ Movement for Growth - 2026 Delivery Plan for Transport (TfWM 2017)
Black Country Transport - Connected for Growth (BCLEP and TfWM 2019)

·   West Midlands Strategic Transport Plan (Core Strategy) - Reimagining transport in the West Midlands (TfWM 2023 and ongoing)
·   West Midlands Local Cycling & Walking Investment Plan (TfWM 2019)
·   Black Country Cycling Strategy (BCA 2021)

Table 3.3 The Economy- Issues and Challenges

Issues

DLP proposed policy framework to address issues

Evidence

Employment Land provision and having a land supply to meet the needs for the borough including potential for assisting/ or seeking assistance from neighbouring authorities via DtC.

Job and employment forecasts considered too low and too high. Updated evidence work has an increase in employment land requirements due to an extended Plan period. The Plan should provide for a range of employment sites capable of meeting a wide variety of investment needs.

  • EDNA October 2023
  • BEAR 2021

Boosting and supporting an economy which provides access to employment and investment

Supporting and providing a thriving, stable economy to ensure future prosperity and job creation. The Plan should provide for a range of employment sites capable of meeting a wide variety of investment needs.

The DLP has a role in addressing these issues by providing a balanced portfolio of employment sites with more energy efficient buildings, protecting, and enhancing existing sustainable employment areas and encouraging new investment, allowing some poorer quality employment sites to be redeveloped for more beneficial alternative uses and enabling communities to share the benefits of economic growth through securing access to new job opportunities and enhanced skills and training programmes.

  • EDNA October 2023
  • Dudley Borough Economic Regeneration Strategy (2024)
  • Dudley Borough Place Based Strategy (2024)

Struggling centres and High Streets-vacancies.

Centres play an important part in supporting economic growth and encouraging investment and contributing to the distinctive spatial character and identity of Dudley as well as being the focal points to sustainably provide services to meet the needs of communities, from shopping, culture and leisure to housing and education.

There are a number of challenges facing the borough strategic centre, its town and district centres such as the prevailing economic climate and changing shopping patterns resulting in high vacant property levels, which mean centres are struggling.

The DLP has a role to play in enhancing the vitality, diversification, and performance of centres, to serve the current and future needs of communities as places to live, shop, work and visit. The Plan can help address challenges facing centres by:
· providing a flexible policy framework to allow centres to diversify and serve realistic ambitions for future mixed use growth;
· ensuring that future growth (particularly housing, education and employment) is well served by the existing network of centres, to help support their future vitality and viability;
· setting out tests to prevent proposals which could undermine centres by causing significant adverse impacts, such as out-of-centre developments.

  • Dudley Annual Centres Health Check 2024
  • Dudley Borough Economic Regeneration Strategy (2024)
  • Dudley Borough Place Based Strategy (2024)
  • Cultural Strategy and Action Plan for Dudley MBC (2024)

Supporting higher education attainment and skills to enable people to access better employment opportunities

Supporting development of skills, access to education and local training opportunities are key issues for Local Plan to ensure residents can benefit from economic growth. The DLP has made provision to support new education facilities in the borough as well as policy to improve access to the labour market and training opportunities.

  • EDNA October 2023
  • WMCA Growth Strategy 2022
  • WMCA Skills Strategy 2024
  • Dudley Borough Economic Regeneration Strategy (2024)
  • Dudley Borough Place Based Strategy 2024

Need for improved transport links to connect people and businesses

Better Connectivity: public transport, walking routes, cycle paths. A balanced approach to transport investment is required that recognises the need to invest in all modes of transport but identifies a priority in increasing the proportion of people using public transport, walking and cycling. Transport policies have been reviewed and updated to place a stronger focus upon active travel and sustainable transport plus potential new strategic investment opportunities.

Current and proposed transport projects will improve connectivity within borough the wider sub-region including Wednesbury to Brierley Hill Metro Extension; Dudley Town Centre Interchange, Birmingham - Halesowen rapid transit corridor, Walsall-Stourbridge tram train extension, corridor improvements to A4123, A461, A456 and A458 (Lye) along with public realm/connectivity improvements and electric vehicle charging infrastructure.

  • West Midlands Strategic Transport Plan - Movement for Growth (TfWM 2016)/ Movement for Growth - 2026 Delivery Plan for Transport (TfWM 2017)
  • Black Country Transport - Connected for Growth (BCLEP and TfWM 2019)
  • West Midlands Strategic Transport Plan (Core Strategy) - Reimagining transport in the West Midlands (TfWM 2023 and ongoing)
  • West Midlands Local Cycling & Walking Investment Plan (TfWM 2019)
    Black Country Cycling Strategy (BCA 2021)

Table 3.4 The Natural and Built Environment - Issues

Issues

DLP proposed policy framework to address issues

Evidence

Planning for the impact of climate change, protecting and enhancing our environment and protecting communities from flood risk

The Council declared a climate emergency in 2020 and pledged to achieve net zero carbon by 2030 and a Carbon Neutral Borough by 2041

The DLP has a key role in addressing these issues by: reducing the carbon emissions from new developments; reducing the need to travel and enabling a shift to more sustainable travel modes; maximising the use of low carbon energy solutions; seeking to reduce the impact of flooding; and enhancing the borough's green and blue infrastructure, to protect its people, its environment and the local economy.

Support for the inclusion of Climate Change policies and strengthening the aims. The DLP contains a suite of new policies designed to help Dudley borough mitigate and adapt to a changing climate at a strategic level in line with the Council's climate change priorities. These policies will need reflect local ambitions and opportunities for growth.

Such policies reflect local circumstances rather than repeat national policies and guidance. The Plan policies will respond to climate change and achieve the Council's aspirations and targets.

  • SFRA 2024
  • Dudley Council and WMCA Climate Change Declaration 2020
  • Dudley Council Climate Change Action Plan 2024

Protecting the green belt and sensitive areas of open space outside the green belt

Substantial number of representations focused upon the need for a strengthened case and evidence for green belt release together with strong opposition to the use of green belt land for development. The case, evidence and approach to development is further detailed in the Plan and supporting evidence.

  • Black Country Green Belt Study (2019)
  • Black Country Landscape Sensitivity Assessment Report - 2019

Protecting and conserving the borough's natural environment and ecological assets.

The borough is rich in both its natural and built heritage and its environmental assets. There is an extensive canal network which has the potential to provide a wide range of ecosystem services, including recreation, land drainage, flood protection, water supply, energy generation, carbon storage, heritage preservation and nature conservation. Protecting our environmental resources and requiring new development to leave biodiversity in a measurably better state than beforehand via Bio-diversity Net Gain, contribute towards mitigating impacts in some of our most valuable landscape and habitat areas and minimise impact on heritage assets

  • Ecological surveys
  • SFRA 2024
  • Water Cycle Study 2024
  • Black Country Local Nature Recovery Strategy 2022

Protecting and diversifying the borough's cultural and tourism assets.

Dudley with its historic and cultural assets is a key destination for tourists, and therefore it is important that the DLP contains policies relating to this. Tourism makes up a significant chunk of the area's economy, and it is important to support this. By proxy to tourism is the provision of cultural facilities such as museums, theatres, and music venues, which are not only an attraction for tourists but also residents and supporting them can help improve the local economy. It is important that the DLP helps create the conditions to have a thriving heritage and cultural sector that not only helps create a sense of place, but helps encourage visitors to the area, and increases employment opportunities and enjoyment for those already living in the borough.

  • West Midlands Regional Tourism Strategy 2019 -2029, West Midlands Growth Company
  • West Midlands Cultural Sector Analysis, Hatch, We Made That, Tom Fleming Creative Consultancy, June 2021
  • STEAM Economic Impact Assessment Report 2019-2022: Dudley, May 2023
  • Cultural Strategy and Action Plan for Dudley MBC (2024)

Ensuring sufficient good quality open spaces and enhancing blue and green infrastructure for residents and visitors to the borough

Green & blue infrastructure is an important aspect of planning for many reasons, and protecting and enhancing existing networks, as well as creating new ones are high on the agenda, especially following the release of the Governments 25 Year Environment Plan and the Environment Act, both of which aim to halt natures decline and to support its recovery.

Dudley Open Space Review identifies where there are surpluses and shortfalls in a range of types of open space across the borough. It identified that natural and semi-natural greenspace covers the greatest area followed by Community Parks. Both of these types of open space had the greatest quantity of public access.

The Open Space Strategy is currently being reviewed and a revised Strategy and Action Plan will be completed in 2025.

The Dudley Playing Pitch and Outdoor Sport Strategy (PPOSS) (2022) The study looked at range of sports pitch and facilities provision. It highlights a shortfall in Grass Pitch provision for football, and this is likely to increase with future demand. Some level of shortfall is identified for all football pitch types, 3G pitches, cricket squares, hockey suitable artificial grass pitches, tennis courts and netball courts. For the most part, the shortfalls identified can be met by better utilising current provision and looking how current stock is managed.

  • Ecological surveys
  • Black Country Local Nature Network Recovery Strategy 2022
  • Dudley Open Space Review 2019
  • Dudley Playing Pitch and Outdoor Sport Strategy (2022)

Ensuring new development protects and enhances the environment.

Protection of the environment, improving air quality, acknowledging the valuable heritage of the borough and requiring new development to leave biodiversity in a measurably better state than beforehand, all contribute towards mitigating impacts in some of our most valuable landscape and habitat areas and minimise impact on heritage assets.

The DLP addresses the incorporation of green & blue Infrastructure assets in development inc through the planting of street trees, creating parks, sustainable urban drainage systems, wildlife areas, hedgerows, and waterways, to name a few. Used in conjunction these can all help improve the provision of green & blue infrastructure across the plan area and create a Nature Recovery Network resulting in benefits for people, nature and the climate.

  • Ecological surveys
  • SFRA 2024
  • Water Cycle Study 2024
  • Black Country Local Nature Network Recovery Strategy 2022
  • Black Country Historic Landscape Characterisation (HLC) 2019

Resource requirements to meet growth

Meeting our resource needs to serve the development of new homes and employment provision.

  • Dudley Minerals Study 2023 Dudley Waste Study 2023
For instructions on how to use the system and make comments, please see our help guide.
back to top back to top