Black Country Core Strategy Issue and Option Report

LCP believe that the Core Strategy should be a total review of all existing policies and proposals contained within the adopted Black Country Joint Core Strategy. There has been considerable change in planning policy since the adoption of the existing Joint Core Strategy and it is best that such changes in national planning policy are dealt with in a total review of the Joint Core Strategy.

LCP note the evidence base listed in Table 1. However, the evidence base is lacking any input from the private sector in terms of their views on the property market in the Black Country area.

London & Cambridge Property (LCP) is one of the UK's largest private owners of industrial and retail property, managing a portfolio in excess of 14 million sq ft which is predominantly held for long term investment purposes.

Within the Black Country Joint Core Strategy Area the company owns some 498,781 sqm of industrial and retail floorspace contained within 23 sites (see attached list and plan). This comprises industrial estates such as Pensnett Industrial Estate (Dudley), Shopping Centres (Wulfrun Shopping Centre, Wolverhampton) and local shopping centres such as (Aldridge Shopping Centre).

Many of these properties have been owned for in excess of 20 years and given that LCP have been continually managing and marketing these premises they have considerable long term experience in the local property market in terms of tenant's requirements, demand etc. We believe that such information is of considerable relevance and importance to the preparation of the Joint Core Strategy and should be taken into consideration as part of the evidence base. Furthermore, the Joint Core Strategy would be more robust if it took into account the future plans of major landowners and investors in the area.

LCP would be happy to meet with officers preparing the Core Strategy to outline their views on the issues affecting them in respect of their property portfolio particularly going forward.

LCP note that a Housing market Assessment Strategic Growth Study is underway. Given that there is an acknowledged shortfall in the wider HMA, LCP believe that in line with the advice in the NPPF that the objective of boosting the supply of housing should be pursued in order to meet the full needs for both open market and affordable housing.

LCP do not believe that the EDNA is appropriate given that it has not taken into consideration the views of companies who own and manage industrial estates in the Black Country. LCP have surplus employment land which is available for employment development but improvements are required to existing infrastructure in order to improve its attractiveness. The Joint Core Strategy should take into account potential proposals for these companies.

LCP agree that a Green Belt review should be undertaken as part of the preparation of the Black Country Core Strategy. A Green Belt review will enable consideration to be given to the identification of the most sustainable sites for future development proposals.

LCP agree that issues relating to future housing and supply for growth together with infrastructure improvements and a review of the Green Belt are all important issues that should be considered. However, other issues which should be included are ensuring that future policies and proposals do not undermine existing Town Centres etc.

LCP have no objections to the Core Strategy's vision and sustainability principles. However, they also consider that an important consideration is the viability of proposals and ensuring that development is not hindered by undue requirements which would make development proposals unviable.

LCP agree that many of the Core Strategy spatial objectives remain appropriate, namely: -

* Focused investment and development in comparison shopping, office, employment, leisure, tourism and culture etc.
* Review of redundant and vacant employment land for a variety of uses.
* Ensure protection and growth in existing Town Centres.
* Upgrading infrastructure and transport links to key employment areas.

LCP have no objection to the retention of Policies CSP1 and CSP2 provided they are updated to deal with relevant new evidence both from a national and local perspective.

LCP support Option 1B which enables a restructuring of other existing growth networks to enable more occupied employment land to be identified for housing.