Intu is strongly of the view that the Strategic Centre must remain the focus for such development over the plan period. Intu is planning for significant new investment at intu Merry Hill (iMH) to ensure it remains a primary retail and leisure destination as part of the designated Strategic Centre of Brierley Hill. Future investment, which it is anticipated will comprise some extensions and new developments, as well as incremental improvement and enhancement of the existing asset, is likely to come forward in self-contained applications. These projects will come forward over the plan period, as demand and occupier interest requires. Planning policy in the future must provide the flexibility to accommodate development coming forward in this way, if growth objectives are to be met and delivered by the market. This response should be read in conjunction with our response to Question 63.

The key issue for the new plan is to bring it up to date so that was is planned for reflects current population and expenditure forecasts and most importantly the future needs of the customers and operators that iMH and the other Strategic Centres serve. We explore some of these issues below in more detail.

The National Planning Policy Framework (NPPF) indicates that planning policies should be positive, promote competitive town centre environments and set out policies for the management and growth of centres over the plan period (paragraph 23). Local Plans are expected to define a network and hierarchy of centres that is resilient to anticipated future economic change (paragraph 23, bullet 3) and needs for town centre uses must be met in full over the plan period and not compromised by limited site availability (bullet 6).

Historic retail trends show that retail expenditure growth generally follows a cyclical growth pattern with the underlying trend showing significant growth over many years. This in turn has fuelled significant growth in retail development in the past. The situation has changed with the growth of home and internet shopping and on-going uncertainty arising from the recession and more recently the vote to leave the European Union. Consumer spending grew rapidly in the mid-1990s, but the recession in 2008 had a significant impact on consumer spending and the demand for retail space. Business and consumer confidence was further weakened by higher unemployment, rising costs and less accessible credit at that time.

Comparison goods expenditure grew in real terms (excluding inflation) by 5.3% per annum between 2006 and 2009, but following the effects of the recession expenditure fell by 2.6% between 2009 and 2010. The recovery from the recession was relatively slow with an average annual growth of only 1.5% between 2010 and 2012. Low expenditure growth and deflationary pressures during this period affected the high street, although Experian's figures indicate comparison goods expenditure only fell in real terms in 2009 followed by limited growth for two years.

Comparison good expenditure growth recovered between 2012 and 2014, with an average annual growth of 4.8%. This growth is indicative of positive signs of improvement in the UK economy and consumer and business confidence in 2014. Experian forecast higher levels of growth in the future, with 5.8% between 2016 and 2018 and an average of 3% per annum from 2019, but still at a lower rate than previous pre-recession trends. Experian recognises that the retail sector is vulnerable to changes in the national and global economies.

Special Forms of Trading (SFT) comprises all non-store retail sales made via the internet, mail order, stalls and markets, door-to-door and telephone sales. Based on ONS data, Experian estimate that the value of internet sales is £42.1 billion and other (non-internet) SFT sales is £7.9 billion, with SFT sales totalling £50bn. Experian information suggests that non-store retail sales in 2017 is 10.7% of convenience goods expenditure and 18.5% of comparison goods expenditure. This remains a relatively small proportion of overall retail expenditure. The growth in internet shopping has been historically strong for certain products e.g. electrical goods, books and music. Despite the continued projected growth in home shopping and SFT, Experian forecast growth in comparison goods retail expenditure will be available to support traditional retail floorspace.

Leisure expenditure including eating and drinking away from the home is also projected to grow and over recent years there has been significant investment in this sector, particularly in the development of cinema with food and beverage outlets with many such developments proposed in town centres. This provides for a more experiential 'day out' visit which in turn increases dwell time and supports a strong evening economy. Experian forecast that leisure expenditure will increase on average by 1.4% per annum, a total increase of 23% between 2016 and 2031 over and above inflation.

In addition to new forms of retailing, operators have responded to changes in customers' requirements and market conditions. The discount comparison sector has also grown significantly in recent years. Many high street multiple comparison retailers have changed their format. High street national multiples have increasingly sought larger modern shop units with an increasing polarisation of higher order comparison shopping activity into larger centres. Small and medium size centres have generally become more focused on food and grocery retailing, lower order (day to day) comparison shopping and a much wider range of non-retail services.

The Black Country Strategic Centres must respond to these changes in order to maintain and enhance their vitality and viability. These trends and the implications they may have on the need and capacity for new floorspace must be the subject of further work commissioned by the Black Country authorities, by way of an updated retail evidence base. The comparison floorspace growth at iMH forecast within BCCS may not be required in the future at the large scale envisaged at that time. Nevertheless, over the plan period, intu considers there will be strong demand for new retail and leisure investment at iMH. The reconfiguration and extension of existing space and the development of new floorspace will occur if policy can provide intu and their tenants with the confidence and flexibility to allow this to come forward as the market, and changing economic circumstances, requires.

Intu requests the opportunity to be consulted on this work in due course, so that the evidence base is prepared cognisant of the needs of iMH and the market for town centre uses more generally. In this way policy will have a far better prospect of facilitating appropriate development to come forward in a way that hasn't been the case with Policy CEN3. Furthermore it will enable far more realistic expectations to be set regarding public transport and other infrastructure that new development might be able to support.