Object

Representation ID: 23368

Received: 11/10/2021

Respondent: West Midlands CPRE

Agent: Gerald Kells

Policy CSP2
In general terms CPRE supports the aspirations of Policy CSP2, and particularly the intention to deliver more homes in urban centres. However, the figures given in CSP2 for housing supply appear to us conservative. The Black Country Centres Study, which was based on evidence predating the pandemic, suggests a reduction in the requirement for Retail Space, both for Comparison and Convenience Shopping.
Para 3.36 identifies the need for a new mix of uses, underpinned by housing in centres. CPRE would urge ABCA to review its approach to centres, adopting realistic assumptions about retail need, and whether some managed contraction is required. If this is done in advance of the Regulation 19 Submission it would allow the soundness of the Plan to be tested and could yield additional much needed housing within urban centres as well as making them more viable in the long term.