Draft Black Country Plan

Comment

Representation ID: 13945

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy CEN1 - The Black Country Centres

London & Cambridge Properties Limited (LCP) is one of the UK’s largest property owners of retail and industrial, managing a portfolio in excess of 16 million sq ft which is held predominantly for long term investment purposes.
LCP own a number of retail centres in the Black Country Local Plan Area and are keen to play an active part in the emerging Development Plan process in order to inform the requisite planning authorities of their property holdings in their receptive areas.
They own the following retail centres: -
Churchill Shopping Centre Dudley
Aldridge Shopping Centre Aldridge
Astle Retail Park West Bromwich
Wulfrun Shopping Centre Wolverhampton
Park Place Shopping Centre Walsall
Quinton Court Shopping Centre Walsall
Rayner Parade Wolverhampton
35-47 High Street Brierley Hill
Centre House Aldridge
Scott Arms Sandwell
The Moors Shopping Centre Walsall
Dudley Street Sedgley

LCP want to ensure that all of these retail holdings are identified within either Town Centre, Tier One or Tier Two or Three centres. LCP will be ontinuing to invest in these centres and require policies to be flexible to allow a range of uses including retail, leisure and residential.
Emerging policies must be flexible given the ongoing difficult conditions with the retail sector at the moment.

Support

Representation ID: 13947

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy CEN2 - Tier One Strategic Centres

Support is given to this policy which seeks to allow a range of uses to be accommodated in Tier One Strategic Centres. This includes proposals for retail, leisure and residential uses. We question the assertion that proposals for commercial and business development that involve more than 500sqm gross of floorspace within the primary shopping areas shall evidence the measures to
which they are compatible with the objectives of sustainable development. It is unclear why 500sqm
gross has been chosen and what evidence is required.
Further information should be provided to clarify these issues.

Support

Representation ID: 13948

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy - CEN3 Tier Two Centres

Support is given to this policy which allows a range of uses within Tier Two Centres, such as retail, offices, leisure, residential, community, health, education and cultural facilities etc. The emerging policy needs to be as flexible as possible to allow a range of uses to ensure that
these centres continue to be viable

Support

Representation ID: 13949

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy CEN4 - Tier Three Centres

Support is given to this policy which allows ‘appropriate’ uses within Tier Three Centres. However, we believe that ‘appropriate’ uses need to be defined and should include the range of uses identified in Policy CEN3 namely, retail, offices, leisure, residential, community, health, education and cultural facilities. The policy should be amended accordingly.

Support

Representation ID: 13950

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy CEN5 - Provision of Small-Scale Local Facilities

Support is given in principle to this policy which allows the provision of small scale use of up to 280sqm gross subject to a range of criteria. The Policy states that the loss of some local facilities will be resisted e.g. convenience shops, pharmacy etc. It is unclear how this criterion would be controlled given that many of these
uses can now change within Class E without requiring planning permission. It is therefore recommended that this criterion be deleted.

Comment

Representation ID: 13951

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy EMP2 - Strategic Employment Areas

London & Cambridge Properties is one of the UK’s largest property owners of industrial and retail, managing a portfolio of in excess of 16million sq ft which is held predominantly for long term investment purposes.
The company’s head office is situated on the Pensnett Industrial Estate which they have owned and managed for in excess of 35 years. Given the scale of the Pensnett Industrial Estate, LCP have found it important to be able to offer ancillary facilities to existing and potential tenants such as children’s facilities, vets, food and drink outlets etc within their industrial estates. Whilst criterion 4 is welcome,Policy EMP2 - Strategic Employment Areas

London & Cambridge Properties is one of the UK’s largest property owners of industrial and retail, managing a portfolio of in excess of 16million sq ft which is held predominantly for long term investment purposes.
The company’s head office is situated on the Pensnett Industrial Estate which they have owned and managed for in excess of 35 years. Given the scale of the Pensnett Industrial Estate, LCP have found it important to be able to offer ancillary facilities to existing and potential tenants such as children’s facilities, vets, food and drink outlets etc within their industrial estates. Whilst criterion 4 is welcome, LCP believe that it should be widened to accommodate a range of other uses for the tenants of these industrial areas. Such additional facilities reduce travel and make these industrial areas more attractive to existing and potential tenants. Such additional facilities reduce travel and make these industrial areas more attractive to existing and potential tenants.

Support

Representation ID: 13952

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy EMP3 - Local Employment Areas

Support is given in principle to this policy which provides for a range of uses within Local Employment Areas. However, LCP believe that criterion 4 should be widened to allow a range of ancillary uses in these employment area. Such uses can include food and drink uses,
children’s nurseries, vets, leisure etc. The criterion should be amended accordingly.

Support

Representation ID: 13953

Received: 01/11/2021

Respondent: D2 Planning Limited

Policy EMP4 Other Employment Centres

LCP support this policy which seeks to allow other employment uses to be introduced in employment use or to be redeveloped for other uses which could include housing. Such an approach is in line with the advice in paragraphs 122 and 123 of the NPPF.