Regional Spatial Strategy Review Phase 2

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

The Regional Assembly proposed Phase 2 changes of the RSS review (dealing with areas relating to housing, economics, transport and waste) were considered at a Public Inquiry between April and June 2009.

It also considered the Government’s proposal for much higher housing numbers set out in a study by Nathaniel Lichfield and Partners.

CPRE submitted detailed evidence to the Regional Assembly on all areas of Phase 2 as well as commenting on the Government Study. We appeared at all the sessions. 

The Government’s input was extremely disappointing with the highest possible housing numbers and little account taken of the implications. We wrote to the Examination Panel to express our concerns about their response. You can read an overview of our objections and our letter to the panel. We will provide copies of our detailled objections on request.

The Panel’s Report was published at the end of September and the Government’s modification are likely to be published at the end of the year leading to a further round of consultation. The new RSS could be adopted before the next General Election, but that is now a very tight timescale.

While we welcomed the fact that the Panel has supported the thrust of the current strategy, which aims to priorities development on previously developed land in cities, we are generally disappointed because the increase in development they have accepted will undermine this goal in effect.

Housing

CPRE has always been 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 proposed 365,000. The Panel has now recommended 397,900 which is much higher but not as high as Government would have liked at up to 445,000.

Just as worryingly the Panel has recommended weakening the policy to phase housing development. This would make it even harder to ensure housing went to the most needy areas first.

We believe such high theoretical levels would lead to the allocation of green field land, particularly around existing Market and County Towns, and allow developers to cherry pick those sites at the expense of regeneration in our major urban areas.

As a result some towns, such as Worcester, which are designated as Settlements of Significant Development, have already made plans for 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.

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

Economic Development

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 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 have increased pressure for industrial development, particularly on greenfield sites and we are particularly concerned that the Panel recommended increasing the amount of long term employment land. This will encourage local authroities to keep unsuitable land on their books or release green field sites before previously developed land.

We are also concerned that they have increase the amount of land for large warehousing sites, despite the serious impliucations for carbon emissions. 

Transport

We are concerned that the housing proposals, especially the latest increase, could lead to demands for new raod 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. While the Panel did agree that new housing would lead to large amounts of new road building, disappointingly they did not put any policy suggestions in place to correct that. We were particularly concerned that they supported a Hereford Bypass despite Government refusing funding earlier this year.

We also 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 were disappointed that the Panel did not adequately question the need Strategic Park and Ride.

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. The Panel acknowledged public concern about aviation emissions which is good, but its continued support for a second runway at Birmingham Airport does not  bode well.

Waste

We generally support the policy goal of dealing with waste close to where it occurs. However it is important that waste projects do not despoil the countryside.

We are also concerned that the policies do not have separate targets for recycling and recovery (e.g. incineration). While we welcome the move away from landfill Government consider recycling to be preferable to recovery and recovery should only be used for materials that cannot be recycled (called residual waste). However, the weakness in the proposed RSS policy, which the Panel supported, is that it is likely to allow long term incineration contracts in places such as Four Ashes in Staffordshire, which would despoil the countryside, rely on commitments for waste that travels a long way, undermining the goal of localising waste services. At the same time it would reduce the incentive on local authorities to increase recycling rates.

31.10.09