Full text:
Thank you for consulting HS2 Ltd on the Draft Local Plan Submission. I can confirm that HS2 Ltd fully supports the ambitions of the local authority to realise the economic and social benefits of the HS2 railway at the heart of the West Midlands in the context of the new HS2 Interchange station. Through ongoing engagement HS2 Ltd will also support the Council in the objectives of developing the UK Central Hub area with both the Interchange station and wider HS2 Phase One scheme.
Having consulted with colleagues across the organisation, including disciplines such as commercial development, delivery, civil engineering, town planning and urban integration, HS2 Ltd has several specific observations and comments to make on the document subject to consultation. However, the following initial points are provided by way of context.
Firstly, as you are aware the government has announced its intention to construct and operate Phase One of a high-speed railway, known as High Speed Two (HS2), between London and Birmingham; and Phase Two between Birmingham and Manchester and Leeds. On 25 November 2013 the government deposited a hybrid Bill with Parliament titled ‘High Speed Rail (London - West Midlands) Bill’. The Bill grants the powers to construct Phase One of the HS2 network. HS2 Ltd is the non-departmental public body responsible for developing and promoting these proposals and the company works to a Development Agreement made with the Secretary of State for Transport.
On 23 February 2017 Royal Assent was granted for Phase One of HS2 and since then there have been two further significant milestones for the HS2 programme, namely; the Government officially giving HS2 the ‘green signal’ on 11 February 2020 and then on 14 July 2020 the Department for Transport giving HS2 Ltd approval to issue ‘Notice To Proceed’ (NTP) to the four Main Works Civils Contractors (MWCC) to commence full detailed design and construction of Phase One. This represented a major milestone for HS2 amidst the difficult and challenging times facing us all currently and marks the point at which our work transitions from scheme design and preparatory works to more detailed design and construction.
HS2 Ltd welcomes fact that the arrival of HS2 in the borough following Royal Assent and NTP is a key feature in the draft Submission Plan, and the Leadership of the Council rightly recognises how the HS2 project represents a unique opportunity, and as such a proper planning policy framework is in place to maximise the benefits arising from this once in a lifetime opportunity.
HS2 Ltd also acknowledges that to help shape that future policy, the plan identifies various potential challenges and what the objectives should be in addressing them. In submitting this consultation response HS2 Ltd wishes to focus on following specific issues which are of relevance to the HS2 project:
1.‘Increasing accessibility and encouraging sustainable travel’ with objectives including: ‘Ensuring that expected levels of population growth as well as delivery of HS2 and UK Central do not compound existing levels of peak hour congestion on the principal road network.’
2.‘Maximising the economic and social benefits of the High Speed 2 rail link and the UKC Hub Area’.
‘Challenges:
• ‘Securing amendment to the HS2 proposal for a Parkway style interchange station with surface car parking, which could undermine efforts to maximise the economic and social benefits of the rail link.’
Objectives:
• ‘Creating a sense of place and arrival via a well-connected and integrated interchange, public realm and development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills, environment and infrastructure.’
• ‘Ensuring appropriate infrastructure is in place that allows the Interchange to be well connected to the nearby key economic assets, including Birmingham Airport, the NEC, local universities and the wider Hub area so that they (and others) can take advantage of the opportunity provided by HS2.’
• Ensuring that the HS2 Interchange prioritises access by bus, cycle, Metro, SPRINT bus rapid transit network, or the Coventry Ultra-Light Rail system rather than the private car.
• Promote cross-boundary connectivity to HS2 from the wider sub-region and key destinations to maximise opportunities for the Midlands Engine for Growth and reduce the need to travel by car.’
3.‘Mitigating the impacts of High Speed 2 and the growth associated with the UKC Hub area’
‘Challenges:
• Impact of construction works on the HS2 rail link and interchange station on the environment, communities and transport network, and subsequently during the operational phase.
• Significant infrastructure requirements associated with the rail link and interchange.
• Impact of the associated economic and housing growth on the Borough’s transport network, communities, environment and its Green Belt.
Objectives:
• Maximise opportunities of HS2.
• Develop a strategy to mitigate the impacts of increased road traffic to/from Birmingham Interchange including public transport provision, junction schemes and environmental measures required.
• To make efficient use of land at the Interchange site by utilising decked car park options in lieu of extensive surface level parking.’
In response to objectives associated with the above points the draft plan should fully reflect the fact that the Schedule 17 submissions (under the HS2 Act) for HS2’s new landmark Interchange station and Automated People Mover were approved by the Council on 1 September 2020 and 15 October 2020 respectively, with the surface car parking awaiting reserved matters permission subject to the completion of a legal agreement (expected imminently), with the planning officer’s report stating the design creates: “an exciting contextual response to its setting”.
Accordingly, HS2 Ltd considers that the base case Interchange station scheme including surface car parking option is already protected through those detailed approvals obtained following Royal Assent for the HS2 Phase One Act of Parliament and associated planning regime. However, as the Council are aware through recent publicity on both the UGC and Arden Cross Masterplan consultations it is also acknowledged that UGC are progressing the necessary design work and planning process for a Multi Storey Car Park (MSCP) option at the site to HS2 standards and requirements.
In that context the draft plan should be clear on a) the requirement to achieve an implementable planning permission for the MSCP in accordance with stakeholder funding timescales as set out in MSCP Steering Group meetings and; b) that UGC will also be responsible for obtaining the necessary planning and Schedule 17 permissions required for the delivery a MSCP option and associated changes to the Interchange station site (note the MSCP will not be permissible under HS2 Act Powers).
HS2 Ltd wishes to clarify that existing high-level assessments of impacts shown in the Arden Cross Masterplan by our appointed design consultants have excluded any analysis of highways, vehicular capacities, sitewide drainage, inclusivity and pedestrian modelling impacts. Therefore, it should be noted that any rearrangement of proposed HS2 carparking and multi-modal provision will have a significant impact on the operation of the new Interchange station and will need to be assessed in detail as the both the ACL Masterplan matures and Draft Local Plan Review progresses further.
Lastly, HS2 Ltd welcomes the identification of the high-speed railway on the Policies Map so proposed allocated sites for development in the draft plan are visible relative to HS2 interests. This is also in line with paragraph 22 of Safeguarding Directions guidance on Local Plans available here: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/844432/LPA_Ph1.pdf.
Conclusion
HS2 Ltd welcomes the opportunity to engage with the local authority through this process of consultation on the draft Local Plan document and is fully supportive of aims to maximise potential development opportunities that help support the HS2 Growth Strategy aspirations for employment, skills, environment and infrastructure in both Solihull Borough and wider West Midlands region. We also look forward to further engagement with the Council as the plan-making process continues.
However, regarding the established local plan soundness criteria and in order to ensure the plan is legally compliant and sound, the Council is also respectfully reminded to consider these representations prior to the document’s submission for examination by a Planning Inspector.
