Object

Representation ID: 23365

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

We also note as a general point that much of the evidence used by ABCA pre-dates the COVID Pandemic and, as is acknowledged in several of the reports, the impact of this, as well as the longer-term impact of other upheavals, particularly BREXIT, remains uncertain. Most immediately the Pandemic has hastened the move towards on-line shopping and more extensive home working practices. These changes will directly affect the need for land and premises and free up opportunities for new housing, particularly in town and city centres, something acknowledged in the Centres Study (Para 3.36) and, even more importantly, an underlining factor in the decision of the Government in December 2020 to direct its housing uplift to the twenty largest cities (one of which is Wolverhampton).
As the attached report explains, there is considerable scope for new land to come forwards for housing from redundant retail and employment land and there are a number of ways this could be accounted for in the Plan, by ringfencing the Wolverhampton uplift (if it continues) for new urban regeneration sites, by identifying additional land in urban centres, by reviewing the criteria on redundant employment land, or by including a significant allowance for larger windfalls, perhaps in line with historic delivery.