Intu agrees that the targets for comparison retail floorspace (and convenience retail floorspace - see response to Question 64) should be revisited as part of this review to take into account current and future trends. This response should be read in conjunction with our response to Question 62.

The updated evidence base study needs to be cognisant of a number of issues:

1. Changes in policy - the National Planning Policy Framework (NPPF) heralded the biggest single change in national planning policy in a generation, and it raises the bar for local authorities in terms of the positive approach and a greater emphasis on the deliverability of plans; plus it requires that needs for main town centre uses are met in full and not compromised by limited site availability.

2. Demographic changes - up-to-date and authoritative population and expenditure forecasts must inform a future review.

3. Changes in retail trends - the NPPF requires the needs of all main town centre uses to be met in full over the plan period (paragraphs 23 and 161) and the review must do this and not just deal with comparison retail and office floorspace. This must embrace F&B and leisure uses which will be an increasingly vital component of the offer of Strategic Centres and other centres.

4. Polarisation - there has been an on-going trend or polarisation of comparison floorspace into a smaller number of larger centres. In light of this its vitally important the Strategic Centres provide for these needs to guard against any such investment going to larger centres outside the Black Country with a consequent diminution of the offer available to local communities.

In order to meet the requirements of the NPPF, the Black Country authorities must provide a robust and credible evidence base to inform the work on the review of the BCCS, taking into account the changes since previous evidence was prepared. The study should establish existing shopping patterns, based on sound empirical evidence and comprehensive customer survey research, including both customers who use facilities in the Black Country and those who shop elsewhere.

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 for iMH in a way that hasn't been the case with Policy CEN3.