Birmingham Friends of the Earth The Warehouse 54-57 Allison Street Digbeth Birmingham B5 5TH Tel: 0121 632

6909 Fax: 0121 643 3122 Email: info@birminghamfoe.org.uk Web: www.birminghamfoe.org.uk Birmingham City Council Planning & Regeneration PO Box 28 Alpha Tower Birmingham B1 1TU 30th March 2012

Dear Sirs Digbeth LDO Consultation Please find below Birmingham Friends of the Earth's response to the Digbeth LDO consultation:

We feel there should be an overall maximum amount of space changing use within the whole Digbeth LDO area for each use list, and as such each use class should have a cap. This would prevent the area being 'overrun' by just one or two particular uses. Without a cap the prevalence of a few limited uses could affect the character and sustainability of the area, and turn it into a monoculture of uses. The goal should be a mixed use area, which the policy as it currently is, is unlikely to deliver. Digbeth is currently an area that provides space for third sector organisations, arts organisations and a great many small businesses and start ups, which stems from the diversity of uses and buildings. We generally feel that permitted change of use area limits should be lowered to ensure that the small buildings and variety of uses and spaces available is maintained. Without this we could see the loss of the incubator space that the Birmingham born businesses of tomorrow need to grow, pushing such innovation elsewhere, which would be detrimental to both Digbeth and Birmingham. A Issues with change of use to D2 use. Could this perhaps allow 'gentleman's clubs' and lap dancing clubs? In addition 999sq.m seems very large for such use changes. We feel this limit should this limit be lower. C Changes between B uses could have consequences in changing large areas of Digbeth into a single use zone (i.e. all offices, all industry, all storage & distribution). Smaller limits need to be applied on the size of permitted use change than the proposed 999sq.m. Again 999sq.m seems a very large change of use. This should this limit be lower. D Again 999sq.m seems a very large change of use. We feel this limit should this limit be lower. E Again 999sq.m seems a very large change of use. We feel this limit should this limit be lower. Development not permitted c: We are unsure why creche and day nurseries are not permitted under the LDO. Digbeth has a significant amount of residents now and may require such facilities now and in the future. Conditions b. and f: Will these be subject to a public right of consultation and response? If not we urge the incorporation of this, especially since noise and nuisance has been a recent issue in Digbeth.
Printed on 100% Recycled Paper

Birmingham Friends of the Earth The Warehouse 54-57 Allison Street Digbeth Birmingham B5 5TH Tel: 0121 632 6909 Fax: 0121 643 3122 Email: info@birminghamfoe.org.uk Web: www.birminghamfoe.org.uk Will changes of use for consequences of development still require full planning consent or conditions? This would include traffic impacts, noise pollution impacts, air quality impacts, ecological impacts, retail/competition impacts, flooding impacts. Developments have the potential to create significant unintended negative consequences which could adversely effect people, our environment, the city's economy, and the sustainable development of the area. We feel these cannot go by unscrutinised by both expert council officers and the public. There should be an application process for this and full right to consultation and response, as well as limited appeal powers. We hope these comments will be useful and we await your decision with interest,

Yours sincerely

Ben Mabbett Planning Campaigner

Printed on 100% Recycled Paper