'Players playing in England are usually bigger, stronger and faster than those in Scotland,' he said. 'I mean no disrespect whatsoever to Scottish players as I know there are some fine footballers in the SPL.
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'Talent is merely one facet of a player's make-up required to make the grade in England.
'Height, pace and power are all needed in equal measure and so few Scots possess all the required qualities to survive.'
The only Scots at Sunderland are goalkeeper Craig Gordon, who was in and out of the side last season, and defender Russell Anderson, a transfer target for newly-promoted Burnley.
Manchester United's Darren Fletcher was the only member of George Burley's Scotland side to feature regularly in the top flight last season, a fact which doesn't surprise Black.
'In the English Premier League today you need to replace outgoing players with new ones who are both experienced and good enough to do the necessary job for the team straight away,' he said.
'You need special players who have, apart from skill, speed and ability, the right kind of character and mentality. They need to be mentally and physically tough â ' England's Premier League is a physical league.
'They need, ideally, to be big, strong and quick. The Premier League is about speed, so they need to be able to pass the ball and receive it quickly and use it effectively.'