Object

Representation ID: 23366

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

The following key points are central to CPRE’s concerns:

1. The policy on Climate Change is inadequate. There should be a specific goal to reduce emissions with specific targets which should be linked to more sustainable location of development.
2. The level of the housing requirement stated is not justified; the Black Country Authorities should be amassing evidence to justify using more up to date figures.
3. The additional housing allocated to Wolverhampton as a result of the 16 December 2020 policy statement should not be included in the overall requirement but identified for additional brownfield sites.
4. There should be a higher allowance for windfalls, including larger windfalls in the plan.
5. While employment land should generally be protected this may also provide additional land. The BEAR analysis, which focuses on protecting employment land, also needs to take account of future trends.
6. The need for retail and office space in City and Town Centres and other Retail locations should be reviewed post-COVID. It may be that some managed contraction of retail space could create centres which are sustainable in the longer term, linked to new housing in centres.
7. The proposed loss of Green Belt should be reviewed. Many of the allocated sites, particularly the large number in Walsall, are in areas which have a high or very high impact on the Green Belt as well as impacts on the environment and on amenity.
The plan includes a large number of policies and we have not been able to comment on all of them in detail. This does not imply we agree with or disagree with other policies not mentioned.