Black Country Core Strategy Issue and Option Report

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Object

Black Country Core Strategy Issue and Option Report

Question 1 - Do you agree that the Core Strategy review should be a partial review, retaining and stretching the existing spatial strategy and updating existing policies? Yes/No; If not, what do you

Representation ID: 254

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Object

Black Country Core Strategy Issue and Option Report

Question 2 - Do you think that the key evidence set out in Table 1 is sufficient to support the key stages of the Core Strategy review? Yes/No; If not, what further evidence is required and, if there

Representation ID: 255

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 3 - Do you agree that the housing need identified for the Black Country over the period 2014-36 in the SHMA, and the anticipated amount of supply, are appropriate and in line with national gu

Representation ID: 256

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Object

Black Country Core Strategy Issue and Option Report

Question 4 - Do you consider the employment land requirement identified for the Black Country up to 2036 in the EDNA is appropriate and in line with national guidance? Yes/No; If not, please explain w

Representation ID: 257

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 5 - Do you agree with the proposed approach to the Black Country Green Belt Review? Yes/No; If not, what additional work do you think is necessary?

Representation ID: 258

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 6 - Do you agree that the key issues set out in Part 3 are the key issues that need to be taken into account through the Core Strategy Review? Yes/No; If not, what other key issues should be

Representation ID: 259

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 7 - Do you think that the Core Strategy vision and sustainability principles remain appropriate? Yes/No; If not, what alternatives would you suggest?

Representation ID: 260

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 8 - Do you think that the Core Strategy spatial objectives remain appropriate? Yes/No; If not, what alternatives would you suggest and how might these changes impact on individual Core Strate

Representation ID: 261

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Support

Black Country Core Strategy Issue and Option Report

Question 9 - Do you agree that Policies CSP1 and CSP2 should be retained and updated to reflect new evidence and growth proposals outside the Growth Network? Yes/No; If not, what changes do you think

Representation ID: 262

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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.

Full text:

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.

Object

Black Country Core Strategy Issue and Option Report

Question 11a - Do you support Strategic Option 1A? Yes/No; If yes, please explain why.

Representation ID: 263

Received: 07/09/2017

Respondent: D2 Planning Limited

Representation Summary:

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

Full text:

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

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