RSS 11 for the West Midlands is being partially reviewed in three stages.

The West Midlands Regional Assembly has submitted its proposed Phase 2 changes of the RSS review (dealing with areas relating to housing, economics, transport and waste) to the Secretary of State.

CPRE submitted detailed evidence to the Regional Assembly on all areas of Phase 2 as part of the development of the preferred option.

A consultation on the proposals began in January 2008, but the Government wrote to the Assembly immedaitely saying it was undertaking a study to consider how housing numbers could be increased. This means the consultation will now continue to at least 23 May and may go on until 30 June 2008.

Housing

Before the Government’s intervention CPRE was already concerned about the proposed increase in housing allocations and published our own hotspots map to show how this might impact on the countryside.

CPRE believes we can provide 285,000 (net) new homes in the region in the next twenty years in a sustainable way, but the Assembly is proposing 365,000.

We were particularly concerned that such high levels will lead to the allocation of green field land, particularly around existing Market and County Towns, which will allow developers to cherry pick sites at the expense of regeneration in our major urban areas.
As a result some towns, such as Worcester, which are designated as sub-regional foci, had already made plans to accommodate high levels of new housing.

But new housing in unsustainable locations would have knock on effects in terms of new road building and green field industrial development, which would inevitable compete with more accessible locations in urban areas.

The January letter from Baroness Andrews which could increase the housing allocations to between 408,000 and 460,000 new houses would only exacerbate problems even more. We will be strongly arguing against it.

Our more detailled case on housing (published in the Birmingham Post) can be viewed here.

Economic Development

However, CPRE, is also concerned about some of the other aspects of the review.
We want to see more industrial development on previously developed sites in our major urban areas and strict control over green field development.

We want to see a change in the balance of office development, so that instead of the majority of new offices being outside our town centres, the majority will be inside.
We do not want to see more large scale business parks (called Regional Investment Sites) on green fields. We believe existing large opportunities, such as Wobaston Road (in Wolverhampton) and Longbridge (in Birmingham) should be developed first.
And we do not want to see massive new warehouse villages (called Regional Logistics Sites) on green field sites. Such proposals not only have a massive impact on the countryside. We believe they also increase traffic and are unsustainable.

The increased housing levels the Government is considering would also increase pressure for industrial development, particularly on greenfield sites, but the implications will be unclear until the study reports.

Transport

We are concerned that the housing proposals,especially the latest increase, could lead to demands for new road building in the countryside which would compete with transport priorities in our cities, further exacerbating the problems of too many people leaving our cities for the countryside.

More specifically, we support the need for demand to be managed, as we cannot continue to accommodate ever increasing traffic growth. However we are concerned that any form of congestion charging does not lead to diversion of traffic or development into the countryside.

We do not support a large scale increase in large Strategic Park and Ride Sites. In our view any new park and ride facilities should serve local communities and not encourage people to travel long distances by car.

We also do not support unrestricted expansion of airports. There is a clear need to control the growth of aviation, which contributes significantly to Carbon Dioxide and other greenhouse gas emissions, and this region need to play its part.

Waste

We generally support the need to deal with waste close to where it occurs. However it is important that large scale waste projects do not despoil the countryside.

29.04.08