Draft Black Country Plan

Ended on the 11 October 2021

(37)3 Spatial Strategy


3.1 The Plan can help achieve sustainable development by ensuring that the Black Country benefits from the right development in the right place at the right time. This development will meet the needs of people living and working in the Black Country, while protecting and enhancing the environment and the unique character of the area.

3.2 The Spatial Strategy as set out in Policies CSP1, CSP2, CSP3 and CSP4, and illustrated on the Key Diagram (Figure 2) provides the overarching basis for the Plan's proposals for growth and infrastructure improvements. This diagram is supplemented by thematic key diagrams for housing, economy, transport, environment, waste and minerals.

3.3 These policies address all the Plan Objectives and Strategic Priorities, but particularly Priorities 3, 4, 5, 7, 10 and 11.


Figure 2 - Key Spatial Diagram

Figure 2 - Key Spatial Strategy Diagram of Black Country


Development Strategy

3.4 Policy CSP1 provides the overarching spatial strategy for the Black Country, setting out the scale and distribution of new development for the Plan period to 2039.

(150)Policy CSP1 - Development Strategy

  1. To deliver sustainable economic and housing growth and to meet strategic planning targets based on the needs of local communities and businesses, the BCA, working with local communities, partners and key stakeholders, will:
    1. Deliver at least 47,837 net new homes and create sustainable mixed communities that are supported by adequate infrastructure.
    2. Deliver the development of at least 355ha of employment land.
    3. Ensure that sufficient physical, social, and environmental infrastructure is delivered to meet identified needs.
  2. The spatial strategy seeks to deliver this growth and sustainable patterns of development by:
    1. Delivering the majority of development in the existing urban area.
    2. Supporting and enhancing the sustainability of existing communities through the focussing of growth and regeneration into the Growth Network made up of the Strategic Centres and Core Regeneration Areas;
    3. Protecting and enhancing the quality of existing towns and Neighbourhood Areas and re-balancing the housing stock by delivering homes supported by jobs and local services;
    4. Delivering a limited number of Neighbourhood Growth Areas in highly sustainable locations on the edge of the Urban Area;
    5. Protecting the openness, integrity and function of the Black Country’s designated and retained Green Belt by resisting inappropriate development;
    6. Protecting the Black Country’s character and environmental assets including heritage assets, natural habitats and open spaces;
    7. Minimising and mitigating the likely effects of climate change



3.5 The economy and population of the Black Country are growing. The BCA need to plan for economic recovery and growth, enhanced business productivity and 47,837 new homes within the plan period. To accommodate this future growth, locations that are both sustainable and deliverable have been identified for development, at levels and in locations that do not breach the environmental capacity of the area.

3.6 The Development Strategy is based on a number of considerations, including:

a) National planning policy.
b) The Plan's Vision, objectives and aims.
c) Environmental constraints,
d) The availability and viability of land for development.

3.7 The Development Strategy has been developed through a comprehensive assessment of a range of alternative options. It is one of 11 Spatial Options considered through this process and corresponds to Spatial Option J – Balanced growth, as set out in the Spatial Options Paper. The Sustainability Appraisal shows that this Option will enable the BCA to meet most of the growth needs within the Black Country in a broad development and delivery focussed manner that takes full account of environmental, climate change, accessibility and social requirements. By promoting the right type and amount of development in the most sustainable locations, the Strategy therefore plays a crucial role in delivering an inclusive Black Country that supports communities to achieve their goals.

3.8 The distribution of growth as proposed in the Development Strategy is summarised in Table 2 below.

(2)Table 2 - Black Country Development Strategy 2020 - 2039


Housing (net new homes) *

Employment Land development (ha)

The Growth Network

Strategic Centres



Core Regeneration Areas






Towns and Neighbourhoods Areas

Neighbourhood Growth Areas



Towns and Neighbourhoods Areas






Small windfall housing and employment sites (outside Strategic Centres)



Total Black Country



To be exported through Duty to Co-operate



Grand Total



*Following appropriate discounts

3.9 The Growth Network – made up of the Strategic Centres and Core Regeneration Areas (Policy CSP2) - is the primary focus for co-ordinated and sustained regeneration and infrastructure investment to support the delivery of regionally significant growth and promote wider benefits to local communities. The Growth Network is the focus for the delivery of these objectives and contains most of the areas where regeneration and land-use change will be concentrated over the plan period. Although this plan does not make development allocations within the Strategic Centres, it sets out deliverable development targets for each centre, based on up-to-date evidence, which will be met through other local plan documents to be prepared alongside or immediately following adoption of this plan.

3.10 The four strategic centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton, and the eight Core Regeneration Areas are already served by an extensive transport system and therefore provide the most suitable locations for economic and housing growth, although improvements are required to enhance connectivity, accessibility and environmental quality.

3.11 While most change and intervention will be focussed on the Growth Network, some large-scale developments will be brought forward outside the network within the Towns and Neighbourhoods Areas (Policy CSP3), to enable vibrant and diverse communities to thrive and prosper. The Towns and Neighbourhoods Areas make up most of the existing urban area and are where most residents live. The overall land use-pattern within the Towns and Neighbourhoods Areas is not expected to alter greatly by 2039, but there will be some incremental change through a mix of permitted and allocated sites, windfall developments and town centre regeneration activity. On the edges of the Towns and Neighbourhoods Areas the Plan identifies a number of employment and housing-led Neighbourhood Growth Areas.

3.12 Strong links will be created between the Growth Network and the Towns and Neighbourhoods Areas, through high-quality design, green infrastructure and transport investment, to help spread regeneration benefits, improve community cohesion and create an effective network of centres.

3.13 The BCA are aiming to utilise land efficiently through the use of previously developed land, vacant properties and surplus industrial land, and maximising housing densities where appropriate, but there is a shortage of deliverable sites to meet housing and economic growth needs. The BCA attach great importance to the ongoing protection of the Black Country Green Belt; however, the green belt boundary is drawn tightly around the urban edges. In order to help meet objectively assessed needs for housing and employment land development, exceptional circumstances to alter green belt boundaries need to be demonstrated.

3.14 Paragraph 137 of the NPPF (2019) states that before exceptional circumstances can be demonstrated, local authorities should be able to show that they have considered and explored all other reasonable alternatives to the use of green belt for development. The BCA have identified and made effective and extensive use of brownfield and urban sites and have also undertaken density uplifts in relation to both existing and new allocations. Sites have been assessed in terms of their accessibility by all modes of transport. There is a significant need to provide for the continued managed growth of the Black Country, to enable it to provide capacity for economic prosperity while recognising and protecting the most sensitive environmental resources and ensuring that proposed development does not adversely affect certain areas unduly.

3.15 Land should therefore be fully assessed not just against its suitability for green belt status but also with regard to the sustainability of the development it might accommodate relative to various issues important to the BCP or the wider area. In this context, the BCA feel they have demonstrated that exceptional circumstances exist to justify the redrawing of green belt boundaries around the urban edge to release land for development.

3.16 The BCA have undertaken an extensive Green Belt and landscape sensitivity assessment to identify land that, if developed, would cause the least harm to the purposes of the Green Belt and to landscape character, is suitable and available for development and that could create long-term and defensible Green Belt boundaries. The Site Assessment Report sets out the details of the methodology used to assess the suitability of sites for development, and the results of that assessment process.

3.17 The overall effect of the strategy is that most housing growth and employment land development will be located in the existing built-up area; this will include 40,117 new homes and 307ha of employment land. An additional 7,720 homes and 48ha of employment land are allocated on sites that have been removed from the Green Belt. Most of these homes and employment land sites are provided in the Neighbourhood Growth Areas and the remainder on smaller sites at the edge of the Towns and Neighbourhoods Areas in the form of rounding-off or through the redevelopment of previously developed land.

3.18 This will allow the BCA to maximise deliverable housing land supply as required by the NPPF, and to ensure land is available in a variety of locations and at a range of scales to meet needs over the whole plan period. The housing trajectory (Appendix 17) demonstrates that the plan will be able to deliver an even supply of housing development land over the Plan period to meet a consistent housing target of 2,517 homes per annum (Policy HOU1).

3.19 The spatial strategy also seeks to protect green spaces within the Black Country, the extensive green belt on the edges of the urban area and the 'wedges' of open land providing both valuable open breaks between settlements and access to the wider countryside, including for wildlife.

(13)Duty to Co-operate

3.20 This Plan will provide for the great majority of housing and employment land needs arising in the Black Country to be met within the Black Country. However, the capacity of the Black Country is finite; it is not possible to provide for all the Black Country's housing and employment land needs within its administrative boundaries, given the circumstances around land deliverability, justifiable constraints and the need to protect the unique character of the area.

3.21 This plan sets a housing target for the Black Country of 47,837 new homes over the period 2020-39, compared to a local housing need for 76,076 homes, creating a shortfall of 28,239 homes.

3.22 For employment land, the EDNA establishes a need for 565ha of land for employment development, an anticipated supply of 355ha and a shortfall of 210ha.

3.23 National planning policy requires this unmet housing and employment land need to be provided for across the Housing Market Area, Functional Economic Market Area (FEMA) and other areas with which the Black Country has a physical or functional relationship.

3.24 As a result, the BCA have worked openly and constructively with neighbouring authorities to help provide as much certainty as possible about how and where the Black Country's full housing and employment land needs will be delivered. The current position is set out in the Draft Plan Statement of Consultation and will be elaborated on in more detail in Statements of Common Ground at Publication stage.

3.25 The BCA recognise that this approach may only address a proportion of the housing and employment shortfall, as it is inappropriate and beyond the powers of the BCA to establish the limits of sustainable development in neighbouring authorities.

3.26 Notwithstanding, the BCA are committed to continued and constructive engagement, through the Duty to Co-operate, with their neighbours to secure the most appropriate and sustainable locations for housing and employment growth to meet Black Country needs. In terms of housing, the engagement will extend beyond the adoption of this plan and will build on the partnership approach developed across the Greater Birmingham and Black Country Housing Market Area to address the combined housing shortfalls of the Birmingham and Black Country authorities in particular.

3.27 Reflecting the efforts of those neighbouring authorities who are supporting the delivery of the Black Country's wider housing and employment land need, where it is shown to be desirable, appropriate, sustainable and deliverable the BCA will support their neighbours in bringing forward land for housing and employment that sits adjacent to the existing administrative boundaries, and will work in partnership to ensure infrastructure needs are met in full across administrative boundaries.


  • Dudley, Sandwell, Walsall and Wolverhampton SHLAAs (2021)
  • Black Country Urban Capacity Review Update (2021)
  • Black Country Employment Areas Review (2021)
  • Black Country Viability and Delivery Study (2021)
  • Black Country Green Belt Study (2019)
  • Black Country Landscape Sensitivity Assessment (2019)
  • Black Country Economic Development Needs Assessment (2017 and 2021)
  • Strategic Transport Evidence
  • Strategic Environmental Evidence.
  • Draft Black Country Plan Statement of Consultation



  • Annual update of SHLAAs
  • Dudley, Sandwell, Walsall and Wolverhampton Authority Monitoring Report
  • Review of Local Plans covering the four Strategic Centres
  • Housing renewal will be delivered through local authority intervention
  • Securing funding to facilitate delivery
  • Working with key partners and delivery agencies.

(1)Issues and Options Consultation Responses

3.28 A large number of responses were made to the Spatial Strategy elements of the Issues and Options consultation. In summary, the majority of representations from residents and community groups supported the focus on brownfield sites and objected to the principle of removing land from the Green Belt for housing and employment development.

3.29 By contrast, the representations from developers and landowners suggested that the BCCS 'brownfield only' strategy will not provide sufficient land to meet future development needs. Instead, the strategy should facilitate removal of land from the green belt for development and move away from the focus on Regeneration Corridors.

3.30 Most respondents agreed that Policy CSP1 of the BCCS should be retained but it needed to be reviewed in the light of new evidence and reflect the location of the new sites allocated through the BCP

Strategic Centres and Core Regeneration Areas

3.31 Policy CSP2 sets out the strategic approach for the growth network.

(35)Policy CSP2 – The Strategic Centres and Core Regeneration Areas

  1. The Growth Network, consisting of the Strategic Centres and Core Regeneration Areas, is the primary focus for regeneration and infrastructure investment to support the delivery of regionally significant growth and promote wider benefits to Black Country communities.
  2. The Strategic Centres and Core Regeneration Areas are the primary focus for new development, regeneration, and infrastructure investment.
  3. The Strategic Centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton will provide:
    1. Re-energised core commercial areas providing a rich mix of uses and facilities, set in a high quality built and natural environment;
    2. The principal locations for major commercial, cultural, leisure, entertainment and community facilities, providing the widest possible range of such facilities appropriate for their catchments;
    3. 9,561 new homes of mixed type and tenure - the majority built at high densities as part of mixed-use developments;
    4. Excellent public transport links, making the centres highly accessible to their catchment areas;
    5. Green infrastructure
  4. The Core Regeneration Areas linking the Strategic Centres will provide:
    1. The principal concentrations of strategic employment areas. These are high-quality employment areas that will be safeguarded and enhanced for manufacturing and logistics activity to support the long-term success of the Black Country’s economy (see Policy EMP2);
    2. The main clusters of local employment land that are vital in providing for local jobs (see Policy EMP3);
    3. The principal locations for new industrial and logistics development - providing 192ha of developable employment land to meet growth needs;
    4. 11,208 new homes in sustainable locations well-supported by community services and local shops, set within and linked by comprehensive networks of attractive green infrastructure with cycling and pedestrian routes;
    5. The focus for investment in existing, new, and improved transportation infrastructure with a focus on public transport routes and hubs which will maximise use of the public transport network by residents, workers and visitors;
    6. Strong links with the surrounding communities and the network of centres and spread the regeneration benefits by knitting together old and new to create a richer, varied, and integrated sense of place.
    7. Green infrastructure



3.32 The re-energising and repurposing of the Strategic Centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton is of fundamental importance to the regeneration of the Black Country, as they are the engines of the Black Country economy and comprise the hubs of the transport networks. They are in the most sustainable locations and are best-placed to provide all sections of the community with easy access to comparison shopping, leisure, entertainment and cultural facilities and office-based employment.

3.33 Much of the housing growth taking place up to 2039 will be concentrated into the Strategic Centres (and locations within the Core Regeneration Areas close to the Strategic Centres), providing an opportunity to enhance their sustainability and viability. Promoting the distinctive strengths and unique opportunities provided by each Strategic Centre will also help to encourage investment. The existing suite of Area Action Plans for Brierley Hill, West Bromwich, Walsall and Wolverhampton will be subject to an early review, to reflect the development targets and strategic objectives and policies within this Plan.

3.34 The Core Regeneration Areas broadly reflect the distribution of large parcels of employment land across the Black Country and accommodate the clear majority of manufacturing and logistics businesses and jobs. The backbone of this network is a system of sustainable transport routes (including rail, metro, bus and for walking and cycling) and the extensive canal system. The key characteristics of the Core Regeneration Areas are:

  1. a) recognised as priority locations for existing or programmed multi-agency public sector intervention;
  2. b) existing or programmed multi-modal transport infrastructure as identified in Strategic Priority 10;
  3. c) clusters of housing / employment development opportunities providing at least 500 homes or 50ha of employment land and / or major concentrations Strategic or Local Employment Areas of at least 100ha.

3.35 The Core Regeneration Areas represent an update of the network of Regeneration Corridors identified in the 2011 Core Strategy. These Regeneration Corridors served the Black Country well, providing a clear focus for concerted intervention and growth. The BCP took the opportunity to review the Regeneration Corridors in the light of more up-to-date information on the deliverability of previously allocated development opportunities, changing infrastructure priorities and to reflect where planned investment and growth has already taken place.

3.36 The strategy for the Core Regeneration Areas reflects two key issues arising from the evidence base – firstly, the need to provide for economic growth through the protection and enhancement of sustainable employment land and premises; and secondly, delivering housing growth through the release of poor quality and underused land to support the ongoing regeneration of the Black Country.

3.37 Achieving the right balance of jobs and housing by 2039 is a key aim of the Spatial Strategy. The Black Country Economic Development Needs Assessment (EDNA) and Black Country Employment Area Review (BEAR) provide key evidence on demand and supply of employment land to 2039 and this work has directly informed the employment land and housing allocations in this Plan.


  • Dudley, Sandwell, Walsall and Wolverhampton SHLAAs (2021)
  • Black Country Urban Capacity Review Update (2021)
  • Black Country Employment Areas Review (2021)
  • Black Country Viability and Delivery Study (2021)
  • Black Country Economic Development Needs Assessment (2017 and 2021)
  • Strategic Transport Evidence
  • Strategic Environmental Evidence


  • Annual update of SHLAAs
  • Dudley, Sandwell, Walsall and Wolverhampton Authority Monitoring Reports
  • Review of Local Plans covering the four Strategic Centres
  • Housing renewal will be delivered through local authority intervention
  • Securing funding to facilitate delivery
Working with key partners and delivery agencies Issues and Options Consultation Responses

3.38 Policy CSP2 is the equivalent of Policy CSP1 in the BCCS. Most respondents agreed that Policy CSP1 of the BCCS should be retained but it needed to be reviewed in the light of new evidence and reflect the location of the new sites allocated through the Plan.

Towns and Neighbourhood Areas and the Green Belt

3.39 Policy CSP3 sets the strategic approach for the Towns and Neighbourhoods Areas and the Green Belt.

(112)Policy CSP3 – Towns and Neighbourhood Areas and the green belt

  1. The areas outside the Strategic Centres and Core Regeneration Areas will provide:
    1. A mix of good quality residential areas where people choose to live;
    2. 27,068 new homes through:
      1. A network of new Neighbourhood Growth Areas providing 6,792 homes, in highly sustainable locations on the edge of the Urban Area;
      2. A limited supply of large-scale brownfield sites providing new homes within the urban area through the repurposing of redundant employment sites and other surplus land;
      3. A supply of small-scale residential development opportunities;
      4. Housing renewal areas;
    3. Clusters of Local Employment Land that provide an important source of land and premises to meet more localised business needs.
    4. 89ha of additional employment land to meet employment needs, of which 36ha will be provide on sites within Neighbourhood Growth Areas.
    5. An integrated and continuous (where possible) network of green infrastructure, walking and cycling routes, as well as a network of centres, health, leisure and community facilities;
    6. Strong and seamless links to regenerated areas in Core Regeneration Areas and Strategic Centres, via access and design improvements to spread regeneration benefits and ensure integration of existing and new communities;
    7. A defensible green belt to help promote urban renaissance within the urban area and that provides easy access to the countryside for local residents; with the landscape safeguarded and enhanced where possible for its heritage, recreation, agricultural and nature conservation value.



3.40 The Towns and Neighbourhoods Area form the majority of the built-up area of the Black Country and this is where most of its residents live.

3.41 As identified in Figure 2, these areas include housing and employment-led Neighbourhood Growth Areas, as well as a number of existing Local Employment Areas. They are supported by a range of town, district and local centres, as defined in Policy CEN1.

3.42 A key spatial priority of the Plan is to support the delivery of a constant supply of new housing development. A significant amount of new housing development will be accommodated in Towns and Neighbourhoods Areas.

3.43 These locations are intended to be places of choice for living, supported by sustainable access to job opportunities and a range of other services and facilities to meet the day to day needs of residents. They will provide housing choice for people, regardless of age and income, to help underpin the areas' economic competitiveness and support the working population.

Housing renewal

3.44 An essential requirement of any strong and stable community is for residents to have access to decent and secure homes. In the past, significant housing market renewal and regeneration programmes have taken place across the Black Country to address poor quality housing and living environments.

3.45 These interventions have been successful, and there are now a limited number of areas where housing market intervention activity is likely to be targeted over the plan period. In particular, housing renewal, involving some demolition and rebuild, is being reviewed in parts of Dudley

Neighbourhood Growth Areas

3.46 Neighbourhood Growth Areas (NGAs) are large sites, or clusters of smaller sites, which have been released from the green belt in sustainable locations on the edge of the urban area (as set out in the Site Assessment Report) for housing or employment development. The housing development NGAs provide at least 250 homes each, creating opportunities to deliver homes of various sizes, types and tenures to meet a variety of needs. The employment NGAs provide at least 36ha of land to provide for a range of investment requirements.

3.47 Neighbourhood Growth Areas have been allocated in a range of locations to provide a reasonable level of choice and to enable several sites to be developed simultaneously. This will help to sustain the rate of housing delivery needed across the Black Country to meet local requirements.

3.48 Given that the new development will generate the need for new infrastructure it is important that the individual sites (as defined in Policy CSP3) in each of the Neighbourhood Growth Areas are master-planned together, regardless of ownership. Phasing plans will be required that set out the triggers for the provision of required infrastructure and legal agreements will need to be put in place to deliver that infrastructure. Where appropriate, masterplans may be prepared through a collaborative process involving the landowner / developer(s) and the relevant BCA. The masterplanning and development requirements of these sites are set out in Chapter 13.

Green belt

3.49 The Black Country is predominantly surrounded by open countryside on its northern, southern and western fringes. This is complemented by a network of green wedges and corridors which effectively bring the countryside and its landscape into the heart of the built-up area. Much of this is green belt and it provides a valuable contribution through a variety of uses. A strong green belt is critical to the Strategy in order to promote urban renaissance within the urban area and provide easy access to the countryside for local residents. The landscape, nature conservation and agricultural land will be protected and enhanced where practical and possible. Policies GB1 and GB2 provide a detailed policy framework for the Black Country Green Belt.


  • Dudley, Sandwell, Walsall and Wolverhampton SHLAAs (2021)
  • Black Country Urban Capacity Review Update (2021)
  • Black Country Employment Areas Review (2021)
  • Black Country Viability and Delivery Study (2021)
  • Black Country Economic Development Needs Assessment (2017 and 2021)
  • Strategic Transport Evidence
  • Strategic Environmental Evidence


  • Annual update of SHLAAs
  • Dudley, Sandwell, Walsall and Wolverhampton Authority Monitoring Reports
  • Black Country Plan Annual Monitoring Report
  • Review of Local Plans covering the four strategic centres
  • Housing renewal will be delivered through local authority intervention
  • Securing funding to facilitate delivery
  • Working with key partners and delivery agencies.

Issues and Options Consultation Responses

3.50 Policy CSP3 is the equivalent of Policy CSP2 in the BCCS. Most respondents agreed that Policy CSP2 of the BCCS should be retained but it needed to be reviewed in the light of new evidence and reflect the location of the new sites allocated through the Plan.

Placemaking – achieving well-designed places

3.51 The environmental transformation of the Black Country is one of the fundamental principles of the renaissance agenda. Placemaking and high-quality urban design are key mechanisms through which this transformation will be achieved


(33)Policy CSP4 - Achieving well-designed places

  1. The Black Country’s ongoing transformation will be supported by the development of places and buildings providing a range of functions, tenures, facilities, and services, intended to support the needs of diverse local communities. The design of spaces and buildings will be influenced by their context; development should enhance the unique attributes of the Black Country’s character and heritage whilst responding to locally identified community needs, changes in society and cultural diversity.
  2. Building designs will be sought that are appropriate to the Black Country, of a size, scale and type to integrate into their neighbourhood. Wherever possible, development proposals will employ sustainable modern technologies to help climate change mitigation and adaptation. The use of carbon-based products, energy and non-renewable resources will be minimised through the efficient design of buildings, choice of materials, layout and site orientation.
  3. All development will be required to demonstrate a clear understanding of the historic character and local distinctiveness of its location and show how proposals make a positive contribution to Black Country place-making and environmental improvement. 
  4. The Black Country will move through a permeable street network that gives maximum freedom of movement and a choice of means of transport, including ongoing support for the provision and extension of walking and cycling infrastructure. To facilitate this, transport proposals of a high design quality and utility will be sought. These should, among other aspects, include connections to and between transport hubs, ensure that interventions make a positive contribution to place-making and increase accessibility and connectivity.
  5. The Black Country will be a safe and secure place to live and work in, through organising the urban environment in ways that encourage people to act in a civil and responsible manner. Development proposals will be required to provide active frontages, well-located, safe and accessible pedestrian and cycle infrastructure and an appropriate intensity of use in centres and elsewhere. Designs should promote natural surveillance and defensible spaces.
  6. An integrated and well-connected multifunctional open space network will be pursued throughout the Black Country, including through the design and layout of new residential and employment developments. This will deliver opportunities for sport and recreation and will help establish and support a strong natural environment. Properly designed and well-located open spaces will help mitigate flood risk, provide space for wildlife and encourage informal recreation for local people 
  7. The protection and enhancement of the Black Country’s historic canal network and the area’s natural waterways will be sought wherever possible through the design and layout of appropriately located housing and employment development and wherever possible by the integration of waterways into those proposals to create attractive waterside development. This will act as a unifying characteristic within the Black Country’s urban structure and landscape.



3.52 The aim of the Black Country Plan is to create the conditions for economic and social growth, which will take place within a safe, attractive and accessible built and natural environment. The BCP also encourages and supports the growth of locations that encourage participation and community engagement. Successful placemaking in the Black Country will foster community stability and incorporate elements that create resilience to adverse economic and environmental impacts. The Black Country enjoys a unique heritage, reflected in its urban structure, which requires a sensitive approach to place-making and an insistence on a high quality of design for proposals that affect the historic built and natural environment.

3.53 Vibrant streets and spaces, defined by surrounding buildings and with their own distinct character, will provide the framework for a coherent and interconnected network of places. These will support ease of movement, social interaction and a sense of personal wellbeing, and will display a clear hierarchy of private, commercial and civic functions

3.54 The Black Country's hierarchy of centres will provide a focus and concentration for essential local services and activities with easy access by walking, cycling and public transport to residential areas, as detailed in policies in the Centres and Transport Chapters and Policy HOU2 – Housing Density, Type and Accessibility. Its diverse, accessible, affordable and active villages, towns and neighbourhoods will encourage commercial activity, promote prosperity and support the well-being of the area's inhabitants.

3.55 The importance of high-quality design in creating places where people want to live, work and invest with renewed confidence is a fundamental plank of both national and local policy. The Government have published national design guidance[3] that supports paragraph 130 of the National Planning Policy Framework (2019), which states that permission should be refused for development of poor design that fails to take the opportunities available for improving the character and quality of an area and the way it functions.

3.56 The opportunity exists to transform the Black Country's strategic centres and core regeneration areas into distinctive places that provide a good quality of life for all who live in, work in and visit them. Investment in high-quality places will result in environmental, economic and social benefits, including community safety, health and well-being, inclusive communities, better public services, environmental sustainability, climate resilience, greater financial value of buildings and improved worklessness. Creating a higher quality of life for the Black Country's communities depends on many factors and will play an increasingly important role in attracting private sector investment and skilled workers.

3.57 The importance of high-quality design and place-making is central to the ambitions of the Local Enterprise Partnership and WMCA. The Black Country Garden City concept was launched by the LEP in 2017 and seeks to utilise existing green, cultural and economic assets to develop attractive places where people want to live, transforming the reality and perception of the Black Country, The West Midlands Design Charter, launched by WMCA in 2020, confirms the commitment of the West Midlands region as a place to drive design innovation and creativity. The Charter aims to secure high-quality design in housing, civic architecture, urban spaces, parks and transport infrastructure. The key themes from the Black Country Garden City concept and Regional Design Charter are reflected in Policy CSP4.

3.58 The BCA have long recognised the potential of public art to enhance the design of new development and have sought the provision of public art on new developments for many years. Public art can be free-standing or incorporated within the overall quality and design of buildings and landscaping and can involve the engagement of local artists. Thresholds for eligible development and the value of contributions will be set out in Local Development Documents.


  • HLC Report (2019)
  • Art in the Public Realm Strategy & Action Plan 2020 – 2025
  • Black Country Garden City Prospectus 2015
  • West Midlands Design Charter 2020



  • DM, legal and funding mechanisms.


Issues and Options Consultation Responses

3.59 The proposed retention of an updated version of Black Country Core Strategy Policy CSP4: Place-Making was broadly supported.

Cultural Facilities and the Visitor Economy

3.60 The Vision for the Black Country involves the delivery of transformational change whilst respecting and promoting the area's unique heritage. The protection, promotion and expansion of existing cultural facilities, visitor attractions and associated activities will ensure their role as key economic drivers stimulating and regenerating the local economy is supported and enhanced, in line with Strategic Priority 9.

3.61 As well as contributing directly to the Black Country's economy, the visitor economy promotes health and wellbeing as well as generating additional demand and growth in supporting services and facilities, which will also benefit residents and businesses.

(9)Policy CSP5 - Cultural Facilities and the Visitor Economy

Development proposals

  1. Major cultural, tourist and leisure facilities within the Black Country will be protected, enhanced and expanded (where appropriate) in partnership with key delivery partners and stakeholders. 
  2. Proposals for new development or uses that contribute to the attractiveness of the Black Country as a visitor destination will be supported in principle, subject to national guidance and policy requirements elsewhere in this Plan.
  3. Proposals for new or expanded facilities or uses should: -
    1. be of a high-quality design,
    2. be highly accessible, particularly within centres,
    3. not adversely impact on residential amenity or the operation of existing businesses,
    4. be designed to be flexible, adaptable, and where possible be capable of alternative or community use.
  4. Well-designed and accessible ancillary facilities will be supported in appropriate locations. Additional facilities that support the visitor economy and business tourism sectors[4] will be encouraged and promoted within centres, in line with policies CEN1 - CEN4
  5. Development that would lead to the loss of an existing cultural / tourism facility in the Black Country will be resisted unless:
    1. the intention is to replace it with a facility that will provide an improved cultural or tourist offer; or,
    2. it can be demonstrated that there would be significant benefits to the local and wider community in removing the use and / or redeveloping the site.

      The Visitor Economy
  6. Improvement and further development of visitor attractions will be supported where appropriate, to ensure that accessibility is maximised and to continue to raise the quality of the visitor experience throughout the Black Country. This can be achieved by: -
    1. enhancing / extending current attractions,
    2. providing inclusive access, particularly within centres,
    3. enhancing the visitor experience, and
    4. delivering necessary infrastructure.
  7. Links should be made to centres and those parts of the Black Country and beyond that are well-connected by public transport, considering the needs of business as well as leisure visitors, to encourage more local use of cultural and tourist attractions.
  8. The canal network is also a significant visitor attraction for the Black Country, providing waterway links to Birmingham, Staffordshire, Worcestershire and beyond. Facilities adjoining and serving the canal network should be maintained and expanded to help provide a network of linked amenities and visitor hubs (see also Policy ENV7 - Canals).
  9. Physical and promotional links to visitor attractions close to the Black Country will be enhanced and encouraged, particularly in relation to Birmingham as a Global City and a business economy destination.

    Cultural facilities and events
  10. The Black Country has a significant cultural history of performance art, especially in relation to live music. To ensure it remains a fertile and thriving location for associated cultural and economic growth opportunities, the retention and protection of venues providing performance spaces, recording facilities and practice amenities will be sought. The provision of new venues and facilities will also be welcomed and supported, particularly within centres.
  11. In cases where adjacent new development would prejudice the ongoing operation of a successful cultural / performance venue, the[5] agents of change" principle will be applied . This will protect the amenities of incoming residents while at the same time it will preserve and protect the existing adjacent use / activity.
  12. The promotion and protection of attractions and events that represent and celebrate the wide cultural and ethnic diversity across the Black Country will be encouraged, including spectator sports such as football and other activities. This will include the protection of valuable cultural and religious buildings and the promotion of cultural, religious and community festivals on a Black Country-wide basis in a range of suitable locations.



3.62 The Black Country has a unique past, having been at the forefront of the Industrial Revolution, which left a rich and varied industrial and cultural legacy as well as an extensive and historically significant canal network. The area's bygone industrial activity and its geological richness is also reflected in a distinctive natural and built topography, consisting of small villages and settlements that retain their individual characteristics (see policy ENV5 and supporting evidence for further details). There are other areas where attractions and facilities are clustered due to their industrial heritage or cultural value (e.g. the Glass Quarter at Stourbridge).

3.63 In addition, the Black Country contains one of the world's few urban geoparks, identified by UNESCO as a single, unified geographical area where sites and landscapes of international geological significance are located (Policy ENV6).

3.64 These assets are attracting an increasing number of visitors to the sub-region and the visitor economy is a key growth sector. Business tourism is also a growing sector, particularly in terms of high-quality hotel and conferencing facilities and the proximity of the Black Country to Birmingham, a global business destination.

3.65 The range and diversity of cultural and tourist assets in the Black Country include a historic built environment, museums and art galleries, markets, music venues and theatres, which are often part of town and city centres; parks and open spaces; and high-level sporting venues. These include, but are not limited to, the following venues and locations: -

  1. Dudley Zoo and Castle
  2. The Black Country Living Museum including Dudley Canal and Caverns
  3. Wren's Nest National Nature Reserve and Limestone Caverns
  4. Dudley Museum @the Archive / Black Country UNESCO Global geopark headquarters
  5. Walsall Art Gallery and heritage attractions centred on the leather industry
  6. Wolverhampton Art Gallery
  7. Wolverhampton's Grand Theatre
  8. The Civic Hall and Wulfrun Hall concert venues in Wolverhampton city centre
  9. Dunstall Park Race Course in Wolverhampton
  10. Sandwell Valley and Park Farm (a working farm and country park with archaeological interest)
  11. Sandwell Aquatics Centre
  12. Bescot stadium – home of Walsall FC
  13. The Hawthorns stadium – home of West Bromwich Albion FC
  14. Molineux stadium – home of Wolverhampton Wanderers FC
  15. The strategic centres of Brierley Hill, Walsall, West Bromwich and Wolverhampton and the town centre of Dudley

3.66 Over recent years, a significant amount of investment has been made at key visitor attractions, particularly associated with Dudley Town Centre such as Dudley Castle and Zoological Gardens, and the Black Country Living Museum. Such investment has increased the visitor offer. Dudley Castle, Dudley Zoological Gardens, the Black Country Living Museum and the Dudley Canal & Tunnel Trust jointly attract some 700,000 visitors per year, with an aspiration to increase visitor numbers to one million by 2023.

3.67 Dudley also commissioned a report by Research Solution called Economic Impact of Tourism in Dudley Borough in 2019, which identified some of the direct and indirect economic benefits of its attractions.

3.68 The sensitive development of heritage and cultural facilities appealing to the very diverse range of local communities will also contribute to social inclusion, health and wellbeing and improvements in quality of life for all sectors of the local population. Culture is also recognised by national government as making a significant contribution to 'place making' and delivering sustainable communities.

3.69 The nature and often the scale of cultural festivals and entertainment events may mean that they will be best delivered at an open-air location. In the Black Country, such sites are likely to include (but are not limited to) key outdoor venues such as West Park, Wolverhampton, Sandwell Valley and Walsall Arboretum. Suitable locations for outdoor events will have appropriate levels of infrastructure, car parking and accessibility to local travel networks and use of them for events and activities should be in accordance with the other policies of this plan and wider legislation and guidance.

3.70 Canals are a significant part of the heritage of the Black Country and form an integral part of both its cultural history and its attraction for tourists; locations include:

  • Walsall Waterfront and Strategic Centre;
  • Wolverhampton Strategic Centre Canalside Quarter;
  • Brierley Hill Waterfront and Canal corridor;
  • Galton Valley Canal Heritage Area, Smethwick;
  • Bumble Hole and Warrens Hall Park on the Sandwell / Dudley border at Netherton / Tividale;
  • Dudley Canal Tunnels, limestone caverns and the Black Country Living Museum;
  • Stourbridge Arm and Wharf area.


  • Economic Impact of Tourism in Dudley Borough in 2017
  • West Midlands Regional Tourism Strategy 2019-29 (2019)


  • Planning permission
  • Promotion of visitor attractions in association with Economic Development Partners in the Black Country, Birmingham and surrounding areas to promote and link cultural and tourism assets in the Black Country.

Issues and Options Consultation Responses

3.71 There was consensus that the approach to identifying key cultural and visitor facilities as set out in BCCS Policy EMP6 should be retained and updated to reflect current priorities

Green Belt

3.72 Green Belts are identified and designated to prevent urban sprawl by keeping land permanently open. The essential characteristics of green belts are their openness and their permanence. The Black Country Green Belt and its detailed boundaries are identified on the Policies Map.

3.73 The green belt is a policy tool that aims to prevent inappropriate development within designated areas. The following policies respond to local circumstances and provide clarity and interpretation of several of the terms set out in the NPPF.

3.74 The protection of the green belt, whilst ensuring the provision of sufficient land to provide for sustainable housing and economic growth, is a key aspect of the Vision and the overarching Strategic Priority of development in the appropriate and most sustainable locations whilst protecting the most vulnerable assets. The policy ensures the delivery of:

a) Strategic Priorities 1, 3, 4, 5, 6, 7, 8, 10, 11 and 12:

and the following Objectives (see Table 1);

b) Climate Change;
c) Housing that meets all our needs;
d) Improving the health and wellbeing of residents and promoting social inclusion;
e) Ensuring a strong, stable and inclusive economy;
f) Promoting sustainable transport and active travel and
g) Transforming our natural and built environment.

(393)Policy GB1 – The Black Country Green Belt

  1. The boundary of the Black Country Green Belt (within the four Black Country authorities of City of Wolverhampton, Dudley, Sandwell, and Walsall) is as defined on the Policies Map for each authority.
  2. For sites that are removed from the Black Country Green Belt and allocated to meet housing, employment, or other needs through this Plan (as listed in Chapter 13):
    1. the design of development will include physical features that define the new green belt boundary in a readily recognisable and permanent way; and
    2. compensatory improvements to the environmental quality, biodiversity and accessibility of remaining green belt land will be secured to offset the impact of removing the land from the green belt, in accordance with national policy.
  3. The Black Country Green Belt will be preserved from inappropriate development so that it continues to maintain its openness and serve its key functions.
  4. Opportunities will be taken to enhance the value and function of the green belt, including through improving footpath and cycleway networks, and retaining and enhancing landscapes, visual amenity, biodiversity and protecting tranquil areas.



3.75 Through the preparation of this Plan, exceptional circumstances have been demonstrated to remove certain areas of land from the Black Country Green Belt to meet housing and employment land needs. Housing and employment allocations made in such areas are called "sites removed from the green belt" throughout the BCP and are listed in Chapter 13.

3.76 Where land has been removed from the green belt, a new defensible green belt boundary has been defined that, where possible, follows physical features such as hedgerows, woodlands, rail lines and roads that are readily recognisable and likely to be permanent. The new green belt boundary remains a robust, defensible demarcation between the open countryside and urban areas and settlements.

3.77 To ensure the Black Country Green Belt continues to serve its key functions, it will be protected from inappropriate development. When considering any planning application, substantial weight will be given to any harm to the green belt. inappropriate development is, by definition, harmful to the green belt and should not be approved, except in very special circumstances, where the potential harm to the green belt is clearly outweighed by other considerations. In line with the requirements of the NPPF, compensatory improvements will be required to the environmental quality and accessibility of remaining green belt land to offset the impact of removing land from the green belt. These will be set out in future Development Plan Documents / master plans or assessed on a site by site basis. These may be informed by supporting evidence of landscape, biodiversity or recreational needs and opportunities including those set out in local strategies, and could for instance include:

a) new or enhanced green infrastructure;
b) woodland planting;
c) landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal);
d) improvements to biodiversity, habitat connectivity and natural capital;
e) new or enhanced walking and cycle routes; and
f) improved access to new, enhanced or existing recreational and playing field provision.
g) linking up areas of woodland, wildlife corridors and footpath network

(3)Policy GB2 – Extensions and Replacement Buildings in the Green Belt

  1. When considering proposals for proposed alterations and additions to buildings within the green belt, in addition to the relevant provisions of the NPPF, regard should be had to the following considerations:
    1. Within the Black Country a number of commercial, educational and community uses that provide local employment opportunities or important community facilities are located in the green belt. To allow for their continued operation, limited, small-scale development will be permitted providing the following criteria are met:
      (1) Proposals for redeveloping existing uses within the green belt will only be permitted if very special circumstances can be demonstrated or the proposal meets the criteria set out in national planning policy.
      (2) Extensions to buildings or new freestanding buildings within an existing developed site and extensions or alterations to existing dwellings may be appropriate where:
      1. Extensions are not disproportionately over and above the size of the existing building(s) as originally constructed;
      2. The scale, materials and general design are in keeping with the character of the buildings and their surroundings; and
      3. It does not lead to a major increase in the developed proportion of the site.



3.78 The BCA recognise that the space needs of community and commercial uses can change and evolve over time and some activities may require additional space. In order to remain in their current premises and to support a thriving community and economy, facilities currently located in the green belt may need to extend or alter their current operational buildings.

3.79 To ensure the openness of the green belt is maintained, any extensions or alterations to buildings in it must not result in additions that are disproportionately over and above the size of the original building. For all non-residential buildings, the 'original building' is taken to be a building as it existed on 1 July 1948 or, if constructed after 1 July 1948, as it was built originally.

3.80 Proposals for extensions to residential properties in the green belt should also not normally represent a disproportionate addition to the volume of the original dwelling. A statement of very special circumstances will be required if the extension is considered to be materially larger than the original building.

3.81 Large parts of the green belt are also identified as being of significant historic landscape character and the BCA will expect particularly high-quality design and materials in such locations, in line with Policy ENV4.


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


  • Through development management and master plans for strategic allocations.

(1)Issues and Options Consultation Responses

3.82 Through representations to the Issues and Options consultation it was made clear that the importance of the green belt in the Black Country should be recognised.

3.83 There were also representations which noted the need for the BCA to undertake a comprehensive green belt review to inform the Black Country Plan review, and those that considered that changes to the green belt boundary would be needed to accommodate the necessary growth






Delivery of net new homes by location, as set out in Policies CSP1, CSP2 and CSP3 and Tables 3 and 4.

Delivery of employment land development by location, as set out in Policies CSP1, CSP2 and CSP3



Investment in the venues and locations listed in paragraph 3.65.

Evidence of capital spending at all venues and locations.


Amount (ha) of green belt with planning permission for inappropriate development each year




[4] This will include the provision of hotels and other accommodation with strong links to key destinations and associated facilities.

[5] This requires the new or incoming development to mitigate and protect its incoming residents and uses against any potential impacts from the extant activities in adjacent properties.


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