Part One: Spatial Strategy and Policies (Regulation 18)

Support

Representation ID: 628

Received: 23/01/2024

Respondent: City of Wolverhampton Council

It is welcome that good progress has been made with the DLP under the current Plan
system, that it is underpinned by work undertaken to prepare the Black Country Plan
(BCP), particularly the shared evidence base and associated policy development, and that
the DLP timetable is aligned with the emerging WLP and Plans for other neighbouring
authorities. This is important given the need to progress a regional solution to addressing
unmet housing and employment land needs, a proportion of which originate in Dudley.
It is recognised that Dudley Council have fully explored all opportunities within the Borough
to maximise development capacity, including increased densities and sites in centres,
whilst protecting viable employment land and premises as necessary, given the evidenced
shortfall of employment development land across the Black Country Functional Economic
Market Area (BC FEMA). In the context of the revised NPPF, it is accepted that it will not
be possible to meet all development needs within the Borough, and that it is necessary for
Dudley to ask other authorities if they are able to contribute towards meeting Dudley needs
through the allocation of land in their Local Plans.

Comment

Representation ID: 629

Received: 23/01/2024

Respondent: City of Wolverhampton Council

It is recognised that Dudley Council have fully explored all opportunities within the Borough
to maximise development capacity, including increased densities and sites in centres,
whilst protecting viable employment land and premises as necessary, given the evidenced
shortfall of employment development land across the Black Country Functional Economic
Market Area (BC FEMA). In the context of the revised NPPF, it is accepted that it will not
be possible to meet all development needs within the Borough, and that it is necessary for
Dudley to ask other authorities if they are able to contribute towards meeting Dudley needs
through the allocation of land in their Local Plans.
The current Wolverhampton position on housing and employment land need and supply is
set out in the Wolverhampton Strategic Housing Land Availability Assessment (SHLAA)
2022, the Black Country Economic Development Needs Assessment (BC EDNA) 2023
and the Draft BCP (2021). On the basis of the December 2022 consultation version of the
National Planning Policy Framework (NPPF), the Leader of the Council committed to
excluding any green belt land from development allocations in the emerging
Wolverhampton Local Plan (WLP).
Taking into account potential capacity on non-green belt land in the Draft BCP, and an
extended Plan period to 2042, the WLP is likely to generate a shortfall of around 11,500
homes and 50 ha of employment development land

Comment

Representation ID: 630

Received: 23/01/2024

Respondent: City of Wolverhampton Council

In terms of employment development land, the BC EDNA concludes that the BC FEMA as a whole has a shortfall of 152ha, however contributions secured through current Statements of Common Ground between the BC FEMA authorities and Shropshire and South Staffordshire Councils have potential to provide 133.6 ha towards BC FEMA needs, which would reduce that shortfall to 18.4 ha.
Given the existing housing and employment development land shortfalls set out above, Wolverhampton will not be in a position to provide land within the emerging WLP to meet either housing needs arising in Dudley, or employment development land need arising in the BC FEMA.
Regarding housing, it is recommended that Dudley Council continues to engage with the work of the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) officer group and the programme of work contained within the Statement of Common Ground as circulated by South Staffordshire Council in 2022. Any solution should be based on an understanding of the pattern of functional and physical relationships across the GBBCHMA including migration and travel to work data so that, where practicable, needs are addressed as close as possible to where they arise.
Regarding employment development land, it is recommended that Dudley should continue to work together with the other BC authorities to close the BC FEMA employment development land shortfall through ongoing DtC activity, with a focus on those areas having a strong or moderate functional economic relationship with the Black Country (as defined in the BC EDNA), and other areas where there is evidence of a functional relationship.