Comment

Representation ID: 291

Received: 19/12/2023

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

The DLP suggests a plan period between 2023 and 2041; although it is noted that the employment land development calculations take account of commitments between 2020 and 2022.

Object

Representation ID: 421

Received: 21/12/2023

Respondent: Pegasus Grab Hire Ltd

Agent: Emery Planning

Policy DLP18 Economic Growth and Job Creation

3.6 The most recent Black Country Economic Development Needs Assessment (EDNA) – 2023 update confirms there is a shortfall in employment land within the borough of 73ha. This situation is echoed across the
remaining Black Country authority areas.

3.7 Whilst Policy DLP18 seeks to address the shortfall through the delivery of at least 72ha of employment
land over the plan period. The plan seeks to achieve this goal through the delivery of 24ha of new employment land on allocated Employment Opportunity Sites, enhancement redevelopment and intensification of existing employment areas and the duty to co-operate. However, there remains a significant imbalance between the areas identified through the draft plan and evidence base suggesting
there is a need for a 3 fold increase on what is currently being promoted.

3.8 Failing to meet the identified need for employment land will cause significant harm to the local economy.
Businesses will not be able to invest and grow in the borough, and jobs growth will be curtailed to the
detriment of residents. This is precisely the situation our client is facing with the uncertainty surrounding
the current temporary use and it is frustrating the growth and development of a successful and highly
valued local business. There will also likely be an impact on commuting patterns or alternately the uptake
of residential allocations as either residents of the area travelling further distances outside of Dudley to
pursue work opportunities and take the related economic activity with them, or alternatively residential development looks to establish itself closer to more available employment opportunities where commuting distances are less and available economic spend is greater.
3.9 The council should be allocating additional employment sites and protecting existing employment sites, such as our client’s site, allocating them as Local Employment Areas providing landowners with the
certainty they need to invest in sites to deliver the intensification and enhancement to existing employment sites which is required to meet the borough’s employment land needs over the plan period.

Comment

Representation ID: 434

Received: 19/01/2024

Respondent: Dudley Labour Group

The Dudley Local Plan ( DLP) has identified a significant shortfall of vital employment land that we feel will
hold back our borough’s economic development. The proposed mitigation measures within the DLP will not benefit our borough and could hinder the effectiveness of the vision to be truly realised.

Of the 72 ha , 23 ha would be needed for manufacturing sector and 49 ha for logistics/storage sectors. These two sectors are the economic drivers for the Dudley’s economy and having a shortfall in these key sectors could be damaging to the growth prospects of these sectors and those employed in them.

The concern is that the FEMA arrangements present a methodology for DMBC to help meet its obligations to deliver employment land outputs , however these will be
elsewhere in neighbouring authorities and not within the borough’s boundary.

Existing Dudley businesses cannot find new larger premises to grow their businesses and employ more local people in the borough.

Comment

Representation ID: 470

Received: 19/12/2023

Respondent: Marlie Civils

Agent: RCA Regeneration Ltd

Policy DLP18 Economic growth and job creation
2.6.The supporting paragraph 9.16 states that 47ha of employment land need within Dudley cannot be met solely within the Borough. As such, whilst we support efforts to deliver employment growth, it is evident that the policy does not go far enough and does not allocate enough sites to meet the need of the Borough. The policy relies on a Statement of Common Ground with neighbouring authorities to deliver Dudley’s unmet need, but given the collapse of the Black Country Plan, we are concerned at the likelihood of this coming forward.
2.7.Additional sites are available, such as Land at New Hawne Colliery, which could be allocated as an Employment Opportunity Site.
2.8.We also consider that the policy should include more explicit reference to support for windfall sites, given the current under delivery baked in to the draft policy.

Comment

Representation ID: 481

Received: 19/01/2024

Respondent: CPRE Worcestershire

WM CPRE supports Part 1 and 2 of this Policy but consider the reference to ‘an evidenced functional economic link’ unhelpful in Part 3 as it suggests that further employment land could be sought in South Staffordshire (and other more rural districts) rather than in the Black Country itself even though the evidence (as set out in our objection to DLP 1 and the attached report) suggests there is sufficient Black Country urban land to meet those needs.

Paragraph 3 should also be changed to emphasize the primary role of brownfield land in Birmingham and the Black Country in meeting any additional housing need rather than other authorities, although I consider that Dudley has identified enough land that it should be able to identify some of that as meeting neighbouring authorities’ needs, and in particular Sandwell.

Support

Representation ID: 510

Received: 19/12/2023

Respondent: Clowes Development LTD

Agent: Harris Lamb

Policy DLP18, I.c. – Clowes support that Dudley will seek to deliver “the development of employment sites outside of the Borough, which have an evidenced functional economic link to Dudley Borough”. The Clowes’ site clearly can demonstrate a functional economic link to Dudley Borough.

Comment

Representation ID: 517

Received: 18/12/2023

Respondent: Lichfield District Council

Employment
It is noted at paragraph 9.16 of the Dudley Local Plan that there is an employment land shortfall of 47 hectares that is to be exported to authorities within the Functional Economic Market Area (FEMA) through the ongoing Duty to Co-operate process and Statements of Common Ground. This employment land shortfall represents 65% of the overall employment land need for Dudley (total 72ha).
It is noted that the total target figure of 72ha is increased to 98ha by adding in 26ha associated with those sites comprising existing operational employment land which are proposed to be re-allocated for housing. Such an approach places an even greater reliance on the unmet need for employment land to be accommodated by other authorities FEMA. Figure 9.1 provides details of the FEMA and it is noted that Lichfield District is assessed as having only moderate economic transactions with Dudley. It should be noted that work on the now withdrawn Local Plan 2040 identified that there is a limited supply of employment sites within Lichfield District and as such LDC was not able to assist in meeting unmet employment land needs.

Object

Representation ID: 539

Received: 22/12/2023

Respondent: Goldfinch Town Planning Services (West Midlands)

The Council should prioritise attracting high quality economic regeneration growth and new inward investment opportunities to the Dudley Metropolitan Borough to help deliver good quality jobs growth for local residents. Making the local area a more resilient and attractive location in which to live, visit, work and invest should be a key local plan priority. Supporting the post COVID-19 fragile local economic recovery, and making the local area more resilient to the current and future economic recessions and global health pandemic events is very important. This is a key issue given that the Black Country sub-region has suffered long term economic decline in its manufacturing industry employment base. Therefore, the emerging Local Plan Review should be taking a sufficiently robust and more pro-active planning policy approach towards these issues with planning policy intervention solutions that actually work on-the-ground, in order to help improve the economic, social and environmental conditions of the local area, consistent with guidance reinforced within paragraph 38 of the Revised NPPF (2023).

Comment

Representation ID: 551

Received: 21/12/2023

Respondent: Nurton Developments Ltd

Comments on supporting evidence base (Economic Development Needs Assessment- EDNA) to the policies submitted.

Overall, NDL consider that there is a much larger shortfall in quantitative terms, between need and supply. In addition, there is a clear qualitative shortage of large strategic employment sites, which the EDNA makes no reference to.

The EDNA has adopted an overly conservative approach. This approach does not accord with the aspirations and ambitions of the Black Country’s Strategic Economic Plan.

The release of significantly greater levels of employment land in the Black Country and its neighbouring authorities, particularly large strategic employment sites, will provide the Black Country with a range and choice of sites. This would confer an important and necessary competitive advantage in attracting inward investment.

Comment

Representation ID: 586

Received: 21/12/2023

Respondent: South Staffordshire Council

Employment Land Need
The latest evidence on employment needs covering the Black Country (Black Country EDNA 2023 update) has identified a need for 72ha of employment land in Dudley. This figure increases to 98 ha.

once replacement for operational employment land sites identified for reallocation to residential development is included.
South Staffordshire Council paused local plan production following completion of a Regulation 19 Publication Plan consultation in December 2022 in light of proposed Government changes to national planning policy. South Staffordshire Council has now recommenced work on plan production but is awaiting the final adoption of changes to national policy before proceeding to an updated Publication Plan (Regulation 19) consultation in Spring 2024. The Regulation 19 Plan was supported by a draft Statement of Common Ground (SoCG) across the South Staffordshire FEMA (consisting of South Staffordshire, Cannock, Dudley, Stafford, Walsall and Wolverhampton), plus Sandwell, as a result of its close economic relationship with the three other Black Country authorities that fall within the South Staffordshire FEMA. At this time, South Staffordshire through this SoCG indicated its position, as set out in our November 2022 Publication Plan, that we have a 36ha (excluding WMI) surplus of employment land that we can make available to unmet needs of the Black Country FEMA. Following the decision by national government to amend national planning policy with respect to Green Belt land releases South Staffordshire Council is currently reassessing the scale of future commitments with a view to producing a revised draft local plan in Spring 2024. To accompany the revised plan SSDC is undertaking an update to the evidence base which will include revisiting the EDNA prior to our next stage of public consultation and this will inform the council’s decisions with respect to future employment land commitments. This will inform an update to the SoCG across the FEMA and our position in relation to contributing to unmet employment needs.
West Midlands Interchange
A Strategic Rail Freight Interchange (West Midlands Interchange (WMI)) is situated within South Staffordshire though this serves a wider market area (including Dudley). Through our 2022 EDNA South Staffordshire Council identified a requirement of 18.8 ha. of the WMI land to meet our labour demand requirements up to 2040. This will be subject to further analysis as part of the update to the EDNA in 2024. South Staffordshire Council has acknowledged that there is surplus employment land at WMI that the council does not require and that could be utilised to meet the unmet needs of the wider market area. Whilst we have taken a more in-depth approach to calculating our share of WMI through our local evidence, we still consider that the 2021 Stantec report1, that considered potential apportionment across the sites market areas based upon population change within each LPA area, is a reasonable basis for determining wider authorities’ potential share of the site given its wider role and in the absence of sub-regional details of labour demand. The Stantec report apportions 67ha of the site towards the Black Country, with a further breakdown suggesting that 14ha of the site could be apportioned to Dudley.

Comment

Representation ID: 626

Received: 05/01/2024

Respondent: South Warwickshire Council

Given the shortfall in available employment land, Dudley Council is encouraged to ensure that efficient use is made of the land that is available. While it may not be possible to require a minimum density as happens with housing land, there may be other ways to maximise the economic benefit from employment land.

Comment

Representation ID: 704

Received: 22/12/2023

Respondent: Canal and River Trust

The Trust requests on-going engagement from the Council on submitted pre-application enquiries, and also encourages developers to seek pre-application advice from us direct.

Comment

Representation ID: 799

Received: 30/01/2024

Respondent: Historic England

DLP18. At this time, we have not had the opportunity to comment on the specific site allocations included within the Plan. We will look at these in the new year and would then welcome a meeting with the Council to feedback our comments and discuss the heritage impact assessment of the proposed sites.

Support

Representation ID: 876

Received: 04/12/2023

Respondent: Mr Ian Tompkins

6. Focusing Industrial development on transport corridors is also a good idea. It would be very good to see installation of wind turbines or solar in such corridors.