OBJECTIONS TO POLICIES OF THE BIRMINGHAM DEVELOPMENT PLAN BY C P R E WARWICKSHIRE

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1 Warwickshire Branch To: Birmingham City Council 41A Smith Street Warwick CV34 4JA Tel March 2014 OBJECTIONS TO POLICIES OF THE BIRMINGHAM DEVELOPMENT PLAN BY C P R E WARWICKSHIRE CPRE Warwickshire has submitted responses on a number of Policies in the which has been published for submission to a public examination. The main policies to which CPRE objects are: PG1 Overall Levels of Growth GA5 Langley Sustainable Urban Extension (6,000 houses in Green Belt east of Sutton Coldfield) GA6 Peddimore (80 hectare employment land development on Green Belt) These objections are reproduced here. Some shorter responses were submitted about public transport and District Centres. PG1 Overall levels of growth The scale of growth proposed in the BDP is unrealistic and excessive. The claim made is that the city will increase in population by 150, This is not backed up in the plan by any detail of past decades' population growth in past decades the rate of growth was far less. The migration out of the city to other parts of the UK that happens naturally seems to have been

2 omitted. The claimed need for 80,000 houses (dwellings) in the period is also poorly justified. It appears to assume continued fall in household size, when (if the average age is falling) household size should increase. There is no sub-regional strategy for the Conurbation against which the scale of growth to be provided can be judged. Options including diversion of growth to the Black Country, which bounds the city on the west and northwest, are not set out in the Plan to show why the choice proposed has been made. The Plan states at para 3.24 that 'Within the urban area there is capacity for some 45,000 homes including bringing vacant land and property back into use and utilising industrial land and some open space that no longer performs its original function'. Delivering more than 45,000 new dwellings by new build or conversion in the Plan period is likely to be impracticable in resource terms. The 6,000 dwellings proposed on Green Belt east of Walmley and Sutton Coldfield should omitted from the plan, with concentration on delivering the 45,000 dwellings proposed to be delivered in the urban area. The Plan should omit that proposal. A Policy to include a review of the Plan (to commence no later than 2020) should be included, which would enable the position on population and housing requirements to be reviewed after the first five years of the BDP. If at that stage there is still an overwhelming need for a major new housing location, options can be reassessed. The proposal for an 80ha employment development of Green Belt land at Peddimore is not justified by the growth aims. Most employment growth is in the City Centre which is accessible and provides high-quality jobs. Employment growth can take place in suburban centres which are more accessible to local residents than either the city centre or an out of town site such as Peddimore. Policy PG1 and Policy GA6 both fail to state that the preferable site for employment is Washwood Heath, within the urban area. It is only because this has been taken (at present) by HS2 Ltd for the HS2 train depot and maintenance sidings that the land is not available for employment use in the Plan. That should be reversed and the land included in the Plan for employment (B1 and B2 uses not B8 warehousing). Reduce the proposed housing numbers within the city area to 45,000. Delete Policy GA5 Langley Sustainable Urban Extension from the Plan. Add a Policy (part of PG1 or a separate Policy) to include a review of the Plan (to commence no later than 2020) should be included, which would enable the position on population and housing requirements to be reviewed after the first five years of the BDP. Delete from Policy PG1 the 80a employment land at Peddimore Insert in Policy PG1 a major employment location at Washwood Heath (Note that a decision on who will have the opportunity to speak at the examination will rest with

3 CPRE Warwickshire GA5 Langley Sustainable Urban Extension Policy GA5 should be deleted. This is a proposal for 6,000 houses on Green Belt land, the largest development on Green Belt that the City has ever undertaken. No threat to Green Belt on this scale has been made since the West Midlands Green Belt was confirmed. The harm to the Green Belt from Policy GA5 would be very great. The setting of the city and the town of Sutton Coldfield would be gravely harmed. The A38 Sutton Coldfield Bypass is not a clear urban boundary; it was landscaped into the countryside 40 years ago, and the landscape is as good to its west as to its east. The Plan states at para 3.24 that 'Within the urban area there is capacity for some 45,000 homes including bringing vacant land and property back into use and utilising industrial land and some open space that no longer performs its original function'. Delivering more than 45,000 new dwellings by new build or conversion in the Plan period is likely to be impracticable in resource terms. The 6,000 dwellings proposed on Green Belt east of Walmley and Sutton Coldfield should omitted from the plan, with concentration on delivering the 45,000 dwellings proposed to be delivered in the urban area. The Plan should omit that proposal. A Policy to include a review of the Plan (to commence no later than 2020) should be included, which would enable the position on population and housing requirements to be reviewed after the first five years of the BDP. If at that stage there is still an overwhelming need for a major new housing location, options can be reassessed. We support the many objections made by more local interests against Policy GA5. Delete Policy GA5 from the Plan.

4 (Note that a decision on who will have the opportunity to speak at the examination will rest with CPRE Warwickshire GA6 Peddimore The proposal for an 80ha employment development of Green Belt land at Peddimore is not justified by the growth aims. Most employment growth is in the City Centre which is accessible and provides high-quality jobs. Employment growth can take place in suburban centres which are more accessible to local residents than either the city centre or an out of town site such as Peddimore. Policy GA6 fails to state that the preferable new site for B1 and B2 employment is Washwood Heath, within the urban area. It is only because the Washwood Heath location has been taken (at present) by HS2 Ltd for the HS2 train depot and maintenance sidings that the land is not available for employment use in the Plan. That should be reversed and the land included in the Plan for employment (B1 and B2 uses not B8 warehousing). Paragraph 5.65 of the Plan 'Why we have taken this approach' fails to state that the Washwood Heath location was preferred by the City Council and that it is the HS2 proposal which prevents it being used for the purpose of providing a high quality new employment area. This explanation should be inserted if the Peddimore proposal is adhered to. The location is the largest area of Green Belt within Birmingham which is not crossed by a major road or other infrastructure. It fulfils effectively the roles of the Green Belt (the five purposes set out in the NPPF). Exceptional circumstances have not been demonstrated for removing the land from the Green Belt. The description at para 5.66 of the Plan The site has low ecological and landscape value and sits within a low lying basin which provides an opportunity to visually contain large scale employment development is not recognised. The land slopes south and provides a green backing to the Minworth and Curdworth area. It is one of the nearest areas of farmed countryside

5 to the centre of the city. It has an agricultural value that should be retained; this value goes unrecognised in the Plan. The heritage sites within Peddimore development area are described at paras 5.68 and They include Peddimore Hall (moat SAM) and ridge-and-furrow fields. These add to the reasons for withdrawing the proposal. The Peddimore proposal would provide 40 ha B1 and B2 uses as up to 40 ha is permitted to be used for B8 warehousing. Warehousing is a poor and wasteful use of land, especially Green Belt land. There is no shortage of B8 floorspace in the West and East Midlands. A location of 40 ha (100 acres) for the higher-value employment uses opens more options than a requirement for 80 ha. The Peddimore location is much more accessible (by car) from residents of neighbouring areas of Warwickshire, Leicestershire and SE Staffordshire than it would be from the areas of Birmingham in which there is a lack of employment opportunities. (Public transport from those areas is not likely to be convenient.) Peddimore seems unlikely to achieve the aim of improving employment opportunities for those areas as opposed to other parts region. By contrast the Washwood Heath location, being adjacent to the Birmingham-Tamworth-Derby main line, would be able to be served directly by a frequent local rail service on the routes Birmingham-Tamworth and Birmingham-Leicester. Delete Policy GA6, or: Replace Policy GA6 Peddimore with a policy GA6 for use of Washwood Heath for B1 and B2 employment; and a policy of opposition to the HS2 Ltd proposal in the HS2 Bill to locate the HS2 train service depot and maintenance complex at Washwood Heath. (Note that a decision on who will have the opportunity to speak at the examination will rest with CPRE Warwickshire