To: Canal & River Trust acting as Trustee of the Waterways Infrastructure Trust; F.A.O. Jeff Peake, Estates Department, Aqua House, 20 Lionel Street, Birmingham, B3 1QA.

Dear Sirs

Re: Dispose of freehold interest in Blowers Green Pumphouse, Peartree Lane, Dudley, West Midlands

In response to your recent public notice for the purposes of Section 121 of The Charities Act 2011, we write to formally object to the above disposal.

The Blowers Green Pumphouse, a listed building (ref SMR 7297), is an important part of the heritage of the canals, having being built in the early 1890s to house a recirculating pump to raise the water levels between Birmingham and Wolverhampton. It is exactly the type of building that meets the Canal and River Trust’s charitable objects, which state:

“2.2 To protect and conserve for public benefit sites, objects and buildings of archaeological, architectural, engineering or historic interest on, in the vicinity, or otherwise associated with inland waterways.”  

CRT, as the freehold owner, is obliged under the above charitable objects and as custodian of the waterways’ heritage, to make sure that it retains heritage aspects under any planning applications. It is also desirable that CRT retains suitable use under the Historic England/Government National Planning Policy Framework for Locally Listed Buildings. Specifically:

“In deciding any relevant planning permission that affects a locally listed heritage asset or its setting, the NPPF requires, among other things, that local planning authorities should take into account the desirability of sustaining and enhancing the significance of such heritage assets and of putting them to viable uses consistent with their conservation”. CRT is also obliged to consider the positive contribution to the local economy that conserving the asset may bring. In addition, the Dudley Development Strategy specifically aims to improve the quality and range of industrial premises in Peartree Lane. Should the freehold be sold, CRT will be powerless to preserve this building for public benefit.

The pumphouse currently provides services to boaters and is on a popular route out of the city, down Delph Locks to the Staffs and Worcs Canal, which is a particularly interesting route for boaters who are interested in industrial heritage. The pumphouse is also at the end of Dudley No 2 Canal, which leads to the Black Country Museum. Over recent years, CRT has sold many historic wharves and buildings that were previously part of the industrial heritage of both the canals and the country. These continual sales will harm the attractiveness of the canals to the new visitors that CRT is seeking to attract. The National Association of Boat Owners (NABO) believes that this will harm CRT’s case when negotiating with the Government for future funding.

NABO asks, on behalf of our members, that you reconsider this freehold disposal. NABO also requests that every effort is made to preserve the industrial heritage that CRT has inherited and resist efforts to sell off important properties such as this.

We look forward to your confirmation,

Stella Ridgway, NABO Chair

13 January 2018