Intu Properties Plc ('intu') supports the vision for the future Black Country as set out in the existing Black Country Core Strategy (BCCS). The three major directions of change and the sustainability principles remain relevant and are supported.

Intu Merry Hill (iMH) has a significant role to play in helping to meet the vision for the Black Country. iMH is a significant provider of goods and services to the local community and wider catchment area. It is one of the Black Country's most significant employers supporting around 6,420 permanent jobs (5,331 FTEs). These employees represent 5.1% of all jobs in Dudley, and over 43% of retail sector jobs. iMH generates £324 million of GVA (direct and indirect) in the local economy.

The existing vision recognises the importance of the successful strategic centres for the economic prosperity of the Black Country. This must remain an integral part of the vision moving forward and the detailed policies that follow will need to facilitate investment at iMH - this hasn't been achieved by the BCCS and it is an issue that must be addressed.

It is incumbent on planning policy to help ensure this long established shopping centre maintains and enhances its role in the future so the economic benefits can be enjoyed by future generations. In order to do this, the shopping centre must evolve and grow and policy must provide for this.

With respect to the sustainability principles nos. 1-4 are generally supported. With respect to no.5, whilst a comprehensive approach to development is a worthy aim and generally supported we don't consider this is a key sustainability principle. Furthermore we consider there must be flexibility in order to avoid the situation that has occurred at iMH where policy pre-conditions have undermined the underlying growth that is being sought and planned for at this strategic centre. If this sustainability principle is maintained, it should refer to a coordinated approach to development - in some cases this might be comprehensive in the way that it's planned, and in others, a broad framework might be a better way to allow the market to respond to opportunities that arise over the plan period.