Intu considers Part a) of Policy CEN8 to be an unnecessary form of control that isn't justified within the existing Policy Justification; nor does it flow from the stated Spatial Objectives. It isn't the role of the planning system to dictate or influence the pricing of parking in Strategic Centres or any other centres. This is particularly relevant to iMH where Policy CEN3 makes car park charging a pre-condition of any future growth at Brierley Hill strategic Centre.

The current policy justification relates to managing travel demand but it also states the potential impact on economic regeneration needs to be considered. With respect to this later point, as outlined in further detail in our response to Question 68, a recent shopper survey undertaken at iMH demonstrates the significant impact introducing car park charging could potentially have upon visitor numbers and trips to iMH and the knock on effects this would have upon retailers, jobs, wealth creation and regeneration of the wider area. The reduction in visitors and the time they spend at the centre is particularly concerning based on the need to maintain or increase visitor numbers and also extend dwell time.

Given this, intu considers it is not appropriate to introduce car parking charges at iMH and this should be recognised through revised policy wording. The most appropriate approach is for policy to instead encourage the use of alterative sustainable transport methods and encourage investment in transport infrastructure.

There are no controls on parking at retail parks (and the majority of superstores) within Dudley or the Black Country, and no proposals to introduce them as far as we are aware. Thus, and as evidenced by the recent shopper survey, should car park charging be introduced at the centre this will encourage more people to shop at out of centre retail parks and superstores, within, and outside the Borough - travelling further by car to locations without good public transport, thereby increasing unsustainable travel patterns. Furthermore, only 7.4% of respondents in the shopper survey said that if car park charging were introduced they would be more likely to use public transport to visit the centre.