Draft Black Country Plan
Purpose of the document
1.1 The Draft Black Country Plan (referred to as the BCP throughout this document) contains planning policies and land allocations to support the growth and regeneration of the Black Country over the years to 2039. It has been prepared and approved for consultation by the four Black Country Authorities (Dudley, Sandwell, Walsall, and City of Wolverhampton), referred to in this document as the BCA.
1.2 The draft BCP contains a Vision for the Black Country in 2039. This is underpinned by strategic objectives and priorities designed to deliver the Vision and associated outcomes. The proposed policy framework will guide and shape development across the Black Country and will set clear parameters for growth and transformation.
1.3 Once adopted, the BCP will provide a strategy for bringing land forward with a clear presumption in favour of sustainable development. It will provide certainty and transparency to residents, businesses and developers about how the sub-region is expected to grow to 2039.
Why does the Black Country need a Strategic Plan?
1.4 The government requires all local authorities to develop a long-term plan that sets out how and where land can be developed over the next 15 years, to meet the growing needs of local people and businesses. The BCP, which sets out strategic policies for the BCA, will provide a policy framework to:
- facilitate the delivery of the right development types to meet identified and emerging needs in the most sustainable places;
- prevent uncoordinated development;
- provide certainty over the types of development that is likely to be approved;
- to meet housing needs between now and 2039;
- attract new businesses and jobs and offer existing businesses the space to grow by meeting employment land needs;
- increase employment opportunities to support the delivery of the Black Country and West Midlands Combined Authority Strategic Economic Plans (SEP), the Local Industrial Strategy and Covid-19 recovery plans;
- address the issue of climate change;
- promote and enhance health and well-being in accordance with the four local authorities' health and well-being strategies;
- protect and enhance designated areas;
- ensuring infrastructure, such as roads, public transport, new schools, new healthcare facilities, upgraded utilities and broadband, waste and sewage disposal, is provided at the right time to serve the new homes and employment provision it supports;
What will the Local Plan replace?
1.5 When adopted the Black Country Plan will replace the Black Country Core Strategy (2011) and significant elements of 'Tier 2' plans in the form of Area Action Plans and Site Allocations Documents, as set out in Appendix 15.
The Context of the Local Plan
1.6 This consultation draft plan has been prepared in the context of national and local guidance and strategies. A range of evidence has been commissioned / undertaken by the BCA to justify the draft spatial strategy and draft policies within this plan, which will be available to view on the BCP website alongside the consultation documents.
National Planning Policy Framework (NPPF)
1.7 The revised NPPF sets out the Government's planning policies for England and how these should be applied. It provides the framework within which locally-prepared plans for housing and other development can be produced.
1.8 Planning law requires that applications for planning permissions are determined in accordance with the development plan, unless material considerations indicate otherwise. The NPPF must be taken into account when preparing the development plan and is a material consideration in planning decisions. Planning policies and decisions must also reflect relevant international obligations and other statutory requirements.
Duty to co-operate
1.9 The Localism Act (2011) introduced a requirement on all local authorities to co-operate with neighbouring local authorities and other bodies with a regulatory or strategic interest in Local Plan issues. The duty requires ongoing, constructive, and effective engagement on areas of plan-making, which may have strategic cross-boundary implications.
1.10 The Duty to Co-operate Statement included in the Draft Black Country Plan Statement of Consultation documents how the BCA have fulfilled the duty through the plan preparation process, and how the bodies referred to in the Act have helped to shape the draft BCP. It is intended to draft and agree Statements of Common Ground with relevant authorities and bodies on key duty to co-operate issues at the BCP's publication stage.
Black Country Local Enterprise Partnership
1.11 The Black Country Local Enterprise Partnership (LEP) has the overall aim of transforming the sub-regional economy by creating the conditions for enterprise to flourish, resulting in greater economic prosperity across the Black Country.
1.12 The Black Country Strategic Economic Plan (SEP) sets out the vision, objectives, strategy, and actions to improve the quality of life for everyone who lives and works in the Black Country, an area with unique assets, challenges, and opportunities. In May 2019 the West Midlands Combined Authority, in partnerships with the region's three Local Enterprise Partnerships (Black Country, Coventry and Warwickshire and Greater Birmingham and Solihull), published the West Midlands Local Industrial Strategy, building on local Strategic Economic Plans.
West Midlands Combined Authority
1.13 The West Midlands Combined Authority (WMCA) seeks to deliver a vision of a more prosperous West Midlands. The Strategic Economic Plan (SEP) 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
1.14 To deliver success for the West Midlands, the West Midlands Local Industrial Strategy was agreed with government and published in May 2019. It sets out a number of priorities intended to help increase the productivity of the West Midlands.
1.15 The adopted Black Country Core Strategy and the forthcoming BCP provide a basis for public and private investment decisions, particularly the Housing Deal agreed with Government in March 2018 and other devolved housing and land funds. The BCA and the WMCA are working together to ensure that investment and delivery in the Black Country continues beyond the existing Core Strategy and into the plan period of the new Black Country Plan.
Previous consultations on the Black Country Plan
1.16 The preparation of the draft BCP commenced in 2016 and included an Issues and Options Consultation in 2017. This used both traditional and online mechanisms to support consultation and drew responses from residents, the development industry and statutory bodies.
1.17 There was concern from residents around the possibility of building on the Green Belt, although developers questioned the brownfield-first approach and whether it was capable of delivering sufficient capacity based upon past trends.
1.18 The consultation demonstrated that there was support for housing to be built in sustainable locations and a desire to protect the environment of the Black Country.
1.19 A summary of the issues and options responses and how they have been addressed in the Draft Plan are detailed within this document, under the relevant policy themes.
Existing Black Country Core Strategy
1.20 The Black Country encompasses the areas administered by Dudley Metropolitan Borough Council (MBC), Sandwell MBC, Walsall Council, and the City of Wolverhampton Council. The four authorities worked together to produce the existing Black Country Core Strategy, which was adopted in 2011. The existing Core Strategy provides the framework for various Site Allocation Documents and Area Action Plans, which themselves set out local policies and site allocations for individual authority areas.
1.21 The existing Core Strategy covers the period between 2006 and 2026. From the outset there was a clear intention to review it five years after adoption, to ensure the spatial objectives and strategy were being effectively delivered and to keep the plan up to date. This is in line with national planning guidance. Rolling the plan forward will also enable the longer-term needs of the Black Country to be addressed. The most contentious issues the Black Country is facing is that both its population and economy are set to continue to grow and as a result there is a need to identify additional housing and employment sites, which are currently beyond the capacity of' the existing Strategy.
1.22 The need for a review has been given even greater urgency by new challenges that have emerged since 2011. The national economic situation has also changed. The existing Core Strategy was prepared as the country was emerging from the global recession of 2008, and the Black Country was recovering from a period of economic and population decline. This was reflected in the Core Strategy in a clear emphasis on the recycling of land previously in industrial use to provide for housing and newer employment activities such as offices. In reality, the manufacturing and industrial markets of the Black Country have remained stable and have expanded in some cases, meaning that the expected surplus of vacant brownfield land has not occurred in practice.
1.23 Looking to the future, the opening of HS2 and the extension to the Midland Metro are likely to have a significant impact on the Black Country within the timeframe of this Plan. There have also been several changes to national policy, especially a revised national planning policy framework and guidance.
1.24 More recently, the COVID19 pandemic in 2020 – 2021 caused a significant shift in the way Black Country residents work, shop and access services. There are likely to be some longer-term changes in the way communities operate that may have implications for land uses, and the BCP will seek to address those issues through the use of robust yet suitably flexible and sensitive policies.
Black Country Spatial Portrait
1.25 Sub-regional Context: the Black Country forms a distinctive sub-region on the western side of the West Midlands conurbation, close to the City of Birmingham. It shares an eastern boundary with Birmingham and to the north, west and south it is bounded by districts within Staffordshire, Shropshire and Worcestershire and is in relative proximity to centres such as Cannock and Bromsgrove. It has a unique economic history, settlement form and topography and is very much shaped by its industrial past.
1.26 The four local authorities have a shared set of social, economic, and environmental challenges and have found it effective to tackle strategic issues on a cross-boundary basis. The authorities have worked closely together for 14 years to establish a clear and collective set of ambitions and directions of travel, expressed in an agreed economic and spatial strategy. This joint working has strengthened and deepened over time – moving from establishing a 30-year Vision in 2003, to adopting a joint Core Strategy in 2011, through to securing funding through the Black Country LEP and the West Midlands Combined Authority in 2017 to deliver priority projects.
1.27 Demographic Trends: the population of the Black Country currently stands at just over one million people and is anticipated to grow further. The Black Country population is extremely diverse, and therefore has the capacity to harness the talents of different groups of people to make for a more robust and resilient economy. The BCP will provide a basis for opportunity for its residents, ensuring the development of skills and learning are linked to communities and growth.
1.28 Economy and Skills: the Black Country has a long industrial history, especially in manufacturing. Until the 1980s the Black Country, together with neighbouring Birmingham, was the powerhouse of Britain's manufacturing economy.
1.29 A legacy of the decline in heavy industry, and the jobs associated with it, has been the difficult ground conditions left behind. Recently however, the economy has grown, and residents' wages have increased. At the same time the employment rate has grown at a faster pace than in England generally (3.5% growth compared to 0.9%) and Gross Value Added in the Black Country was £21.7bn in 2020, an eight-year high (Black Country Consortium, 2020).
1.30 The challenge is to keep that momentum, particularly in the light of the Covid-19 pandemic, ensuring growth is sustainable and that the Black Country Plan is part of that process through providing the right sites for economic growth.
1.31 The West Midlands was one of the hardest hit parts of the UK during the collapse in the economy in the first wave of the Covid-19 pandemic, official figures have shown. The BCP therefore needs to provide the basis for delivery, making sure that development is sustainable and that the Plan is part of that process through providing the right sites for economic growth.
1.32 Skills: a long-standing skills challenge exists in the Black Country, with too many people having no qualifications and not enough holding higher qualifications. This leads to sustained weaker employment and lower earnings. However, latest data shows that our average earnings are growing faster than national average and so gap is reducing. Black Country residents working full-time earn £27,839 as of April 2020 (+£1,505 from April 2019), which is a 5.7% increase compared to 3.5% nationally. Data has also shown that the percentage of Black Country residents with NVQ4+ qualifications is increasing. The percentage of those with no formal qualifications fell by over 30% between 2007 and 2019. More recently, the number of people with no qualifications decreased from 121,800 in 2019 to 91,600 in 2020. Whilst employment and earnings in the Black Country have remained below the national and regional average, the gap has closed recently. In line with national trends, the number of apprentices has decreased. Several further and higher education opportunities are available, including the expansion of Wolverhampton University, the Elite Centre for Manufacturing Skills - National Foundry Training centre in Tipton, a specialist Music Institute at Cable Plaza and the Very Light Rail National Innovation Centre training college and test facility in Dudley. These and other outlets are providing a diversifying and expanding portfolio of training and upskilling opportunities.
1.33 Housing: the Black Country is continuing to see new homes built – an increase of 2,500 this year to a total of 493,000 for the growing population, which is expected to reach 1.2 million in 2039.
1.34 Health and Wellbeing: the Black Country has lower rates of physical activity and higher rates of obesity than the rest of England. In addition, the Black Country has issues with alcohol abuse, depression and social isolation.
1.35 It also has lower life expectancy and higher rates of multiple deprivation, of children living in poverty and of unemployment than the average for England. Life expectancy is lower than both the West Midlands as a whole and England and higher mortality rates are suffered by the population.
1.36 These and other issues, which negatively affect the physical and mental health and wellbeing of residents of the Black Country, are all influenced by the built and natural environment.
1.37 Transport: there are 25 towns and four major strategic centres in the Black Country (Brierley Hill, Walsall, West Bromwich, and Wolverhampton). The denseness of the urban area and the number of centres create particularly complex movement patterns and have led to a complicated transport network. Buses are the most important method of public transport travel in the Black Country, but they face challenges especially from declining speeds due to congestion.
1.38 The Black Country is connected to the main line rail network at Wolverhampton and Sandwell and Dudley Stations. Improvements in the public transport network (especially the Wednesbury to Brierley Hill Midland Metro Extension) will better connect the Black Country into the national and local rail network and improve mobility across the Black Country.
1.39 For work, travel by car remains very important in the Black Country, reflecting in part the complexity of the urban area and declining bus speeds.
1.40 Centres: centres play a crucial role in the priorities identified in para 1.2 by sustainably providing services to meet the needs of communities from shopping and leisure to housing and education. The Black Country's four Strategic Centres provide the focus for shopping, particularly non-food, commercial, leisure and employment; complemented by its town centres (including Walsall's district centres) and network of local centres, serving the Black Country's communities. Changing shopping patterns are presenting many challenges, such as vacancy levels, which mean many centres are struggling.
1.41 By ensuring future growth in the Black Country, particularly housing, can be served by the existing network of centres, this can help ensure their future vitality and viability.
1.42 Black Country Broadband: the Black Country is part of the West Midlands 5G testbed. This is the UK's first large-scale multi-city test bed (with a hub in Wolverhampton) centred on using 5G technology in the health, construction and automotive sectors to assist in the drive for economic growth and to benefit the population through new digital technologies and digitally transformed public services. The Black Country performs very well, when compared to the rest of the Midlands – in large due to successful Black Country Superfast Broadband investment where over 60,000 premises were enabled to access superfast broadband.
Challenges and Issues
1.43 The following summarises the key strategic challenges and opportunities that have arisen since the Core Strategy was adopted in 2011. These issues are the main reasons why a review is needed, and form the main opportunities and challenges which the Plan Strategy, objectives and suite of policies and proposals seek to address:
- Providing good quality housing that meets the needs of a growing population - the Plan needs to identify sufficient land for housing to meet the needs of people who are likely to live in the area over the period of the plan.
- Supporting a resurgent economy, which provides access to employment and opportunities for investment - the Plan should provide for a range of employment sites capable of meeting a wide variety of investment needs.
- Reviewing the role and extent of the Green Belt - evidence suggests that there will be significant housing and employment needs and a deficit in the brownfield land supply within the Black Country, which has resulted in the need for an assessment of the Green Belt to help identify potential areas for growth.
- Supporting strong and competitive centres - to address the health and enhance the vitality and viability of our centres and ensure we have realistic ambitions for growth. The Plan should provide a flexible policy framework to allow centres to serve the future growth identified in the Black Country (particularly Housing and Employment), diversify and provide strict tests to defend against proposals that could undermine centres, such as out-of-centre developments.
- Climate change and protecting and enhancing the environment - the Plan needs to address the challenge of mitigating and adapting to the impacts of climate change in ensuring sustainability principles are embedded across all areas. It will also need to create a strategy for the enhancement and protection of the Black Country's environment and make provision for new environmental infrastructure required to support sustainable growth across the Black Country.
- Keeping the Black Country connected - 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.
- Providing infrastructure to support growth - physical and social infrastructure is 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.
- Health and Wellbeing- The role of the environment in shaping the social, economic and environmental circumstances that determine health and wellbeing is increasingly recognised and understood (see Figure 3, chapter 5). The BCP seeks to help address this.
Draft Black Country Plan
1.44 The Plan is structured as follows:
- Section 1 sets out how the Plan has been prepared and establishes the local context, highlighting the strategic challenges the Black Country faces.
- Section 2 provides the spatial vision, strategic objectives and priorities of the Plan that provide the basis for the policy and spatial approach.
- Section 3 sets out the overall spatial strategy for the Black Country, containing overarching policies intended to deliver the vision and objectives of the Plan.
- Sections 4-12 set out the detailed policies, organised by themes and reflecting the role of the Vision in delivering sustainable growth for the Black Country.
- Section 13 is divided into four chapters related to each of the four Black Country authorities (Dudley, Sandwell, Walsall and Wolverhampton) and identifies the site allocations for each authority.
- Section 14 outlines how the Councils will monitor and manage the Plan in terms of the delivery of the spatial visions, strategic objectives and implementation of the strategy.
1.45 The Appendices provide detail on proposed changes to existing plans as a result of the Draft Plan, further information in relation to the Black Country's centres and the Black Country Nature Recovery Network and a glossary of terms.
 See NPPF paragraph 21 for definition