The Lost Decade

As we reach the end of a decade without any form of strategic planning in the West Midlands, it’s a good time to reflect on how we got here and what might happen next.

Many will have read my occasional blogs on this subject [this one from 2016]; let’s face it, things move at such a glacial pace that regular updates would be hard to differentiate, and I recently participated in Sam Stafford’s BCEG-sponsored 50 Shades Podcast which discussed this topic [https://pod.co/50-shades-of-planning/how-to-plan-strategically-without-strategic-planning].

I’ve also enjoyed lecturing to MSc students at the University of Birmingham where I coined the phrase “the lost decade” – the period since the abolition of the RSS in 2010. I use the West Midlands as a frame of reference because it’s hard to pin down even what it is anymore, and that is part of the problem.

When I started my career thirty years ago, we had Strategic Planning Guidance for the metropolitan area – the seven urban districts which are now the electoral base for the West Midlands ‘Metro’ Mayor. This then expanded into the West Midlands Region, encompassing the surrounding four counties, including the city of Stoke. Since RSS abolition, we now have a resurgent West Midlands but it is an idiosyncratic mix of the Metro Mayoral demesne, the three LEPs that form the Combined Authority’s economic area, and then the patchwork of authorities who are signed up to the WMCA including the likes of Telford & Wrekin. It’s hard to tell who is in and who’s out.

For me, there are a number of interplaying issues when looking back over this decade:

• It is always difficult to distinguish the impacts of the market from the effects of planning. This decade started with a deep recession and we have spent half of it recovering and then at least part in a mini-boom. This has had differential impacts on the region with some areas clearly not benefitting at all, which is reflected in the seismic political shifts we have seen, culminating in the General Election in December 2019. We keep talking about inclusive growth, but only see communities moving further apart. I’m not convinced the new political landscape will change that even with talk of “levelling up”.
• Planning is clearly not just a numbers game and the qualitative outcomes are absolutely what we should be judged on, but you have to start with some sense of the scale of need, and then justify why you might not be addressing those needs, and look at what the consequences might be. This just isn’t being done adequately if at all.
• Strategic planning is about making long term spatial choices and sadly, its absence or shortcomings are only evident as things unravel; so the fact that housing delivery is increasing and broadly on target at the present time is not a good indicator that all will be rosy through the 2020s with our eyes currently fixed on 2031. I believe we are storing up problems.
• Local plans take a long time to process. Look back at this decade and how many authorities have done more than one round of local planning? The requirement to review every five years is only a request to consider reviewing ‘after’ five years, and with a local plan typically taking around five years to take through to adoption, the reality is that plans get updated once every ten years. That means the problems we are storing up from this ‘lost decade’ will only emerge well into the 2020s and that will be too late to put things right.

The Birmingham shortfall

The central theme of this decade in the West Midlands has been the Birmingham shortfall. Again, I’ve written about this before [see Nobody Said It Was Easy] and I must sound like a broken record but it bears repeating: this time as a countdown through the decade.

• In 2010, we still had an approved RSS for the West Midlands, which covered the period to 2021 but, after abolition, Birmingham City Council began consulting on a draft Core Strategy considering three options from 50,000 to 65,000 extra homes by 2031.
• In 2011, the Census showed that the population of Birmingham was increasing faster than expected, and was anticipated to grow by 150,000 by 2031.
• In 2012, the Council consulted on its revised Options post-NPPF, which now reflected anticipated growth of 80,000 households by 2031. The view was that urban capacity was a maximum of 50,000 and there would be a 30,000 shortfall, so consideration was given to the release of Green Belt around the city’s fringe.
• In 2013, the Council produced its SHMA and a Technical Paper on Housing Targets to 2031. The latter acknowledged the shortfall could be as much as 33,000 and work was underway with adjoining authorities to determine how this would be met, with the promise of a Strategic Housing Study for the whole HMA.
• 2014 saw submission of the BDP for examination, clarifying the Objectively Assessed Need for the city as 89,000, a supply of 51,100 including 5,000 removed from the Green Belt at Langley, leaving a 37,900 shortfall. Chris Young and I managed to get all the other 13 HMA authorities to turn up to the DTC session at the examination (it appeared that only a couple were planning to show up, so we asked the Inspector to make it a three line whip). They each explained how they couldn’t be expected to meet the Birmingham shortfall until it was confirmed through adoption of the plan, then they would need to reach agreement on how much each could take, and this would depend on how much everyone else was willing to take. The Inspector asked directly when all this was likely to be brought to a conclusion, and he was told by the middle of the following year!
• 2015 was never going to bring matters to a conclusion though. The Inspector’s interim findings required the Council to do more work on Sustainability Appraisal and housing need, although it did confirm they had satisfied the Duty to Co-operate (a low bar if ever there was one). The final instalment of the Strategic Housing Study was published, which arrived at a slightly different but confusingly similar figure for the overall HMA shortfall of 37,500 which it said was 90% accounted for by Birmingham (which would make it about 33,750), and said that Green Belt release would be needed (the basis for exceptional circumstances).
• 2016 finally saw the Inspector’s report published, endorsing the plan and its approach to addressing the shortfall, albeit firmed up into proposed Policy TP47. He had been led to believe that the Strategic Housing Study and a GBSLEP ‘Spatial Plan for Recovery and Growth’ were the solution, which we now know was not to be the case. He also remarked that three years was a realistic period within which local plans should be reviewed to bring forward proposals to meet the shortfall in full (again, this has not been the case). Of course, there was political delay to the plan’s adoption due to Andrew Mitchell’s challenge to the release of Langley from the Green Belt.
• In January 2017, the plan was finally adopted and the effect of Policy TP47 was to make 10^th January 2020 the deadline for meeting the shortfall in plans “at examination”. By this point, the Spatial Plan for Recovery and Growth had been abandoned, as we had the newly devolved West Midlands Combined Authority (WMCA), whose Land Commission report early that year recommended preparing a ‘spatial planning framework’ [see Turn on all the taps]. The absence of any strategic planning powers for the incoming Mayor however, meant that his would be a convening power and, in his own words, he would “knock heads together” to make sure the housing shortfall was addressed. The WMCA’s Spatial Investment and Delivery Plan (SIDP) has become a proxy for the spatial planning framework but is little more than a compendium of existing plan proposals to underpin the Mayor’s Housing Deal.
• In 2018, the Greater Birmingham HMA authorities published a Strategic Growth Study prepared by GL Hearn and Wood, which revisited the earlier Housing Study work to 2031 and looked ahead to 2036. It found that the shortfall had already reduced to 28,150 by 2017 but that, to 2036, there would be a further 61,000 homes to be found. A number of Council leaders immediately distanced themselves from the report and it became more and more apparent there would be no agreed solution. The year ended with a Housing Position Statement produced by the HMA authorities claiming the shortfall had now reduced to 11,000, albeit based on gross supply figures applying no discount as had been recommended. These figures have not been tested.
• 2019 has been the one year of the decade where arguably the least has happened to move things along and so we enter 2020 and the impending shortfall deadline of 10^th January.

The Deadline Approaches

The promise of an updated Housing Position Statement by the end of the year has fallen away and instead we have to rely on Birmingham’s annual monitoring report (AMR) which was put before Cabinet in December. This has a useful section on the Duty to Co-operate and Progress on Addressing the Housing Shortfall [Birmingham AMR 2019].

The report determines there is no need for a review of the BDP which would be triggered says Policy TP47 “if it becomes clear that progress is falling short of the level required…. to deliver housing growth to meet Birmingham’s needs”. Key indicators include “failure of a relevant Council to submit a replacement or revised Local Plan, providing an appropriate contribution towards Birmingham’s housing needs, for examination within three years of adoption”.

The report sets out the progress that has been made but observes that, whilst not all local plan reviews across the HMA have been submitted for examination by Jan 2020 this is “not due to lack of co-operation but rather the time-consuming and complex nature of the plan preparation process itself”. The BDP Inspector, however, in 2016 had concluded that three years was ample time as seven authorities had already committed to local plan reviews. So what progress has been made?

• Stratford’s Core Strategy was already adopted by the time the BDP reached that stage, and through its draft Site Allocations Plan, it appears that the understanding between the authorities is that they are contributing 2,720 with a possible further 600 and whatever comes forward from Reserve Sites. This is somewhat at odds with the original MOU which talked about 3,300 and there is no reference in the Coventry and Warwickshire MOU to the split of 5,440 between HMAs. Furthermore, Stratford’s spatial strategy has been to focus additional growth towards new settlements in the south and east of the district beyond the Green Belt, as far away from Birmingham as possible and not accessible by rail. The Strategic Housing Study by PBA recommended as far back as 2014 to consider growth along rail corridors and this was reaffirmed by GL Hearn in 2018, but there are no proposals that follow this advice.
• North Warwickshire, another of the authorities split between two HMAs, was the next to come forward with proposals to accommodate up to 10% of the Birmingham shortfall (3,790) plus 620 attributable to an economic uplift. However, this plan is still at examination, having started in late 2018 with the last hearings in April 2019, and the Inspector is not yet in a position to report. One of his main concerns was to understand whether the Council considered meeting the shortfall to be an aspiration or part of its requirement. They do however at least pass the “at examination by Jan 2020” test. No other authority does.

So, in strict accordance with Policy TP47, the amount of the shortfall which has been addressed is at best is 7,730 or around 20%. Of course, if the shortfall has really reduced to 11,000 or less, this could be regarded as ‘job done’.

However, as Chris Young QC has pointed out to me (and he is absolutely right), the only shortfall in an adopted planning policy is 37,900 and neither the status of the revised shortfall figures nor the proposals to meet it would pass any evidential test – they have not been made available for independent scrutiny.

As for the other progress being made by authorities not yet at examination by January 2020 (so those failing Policy TP47 basically):

• Solihull has made a number of attempts to kick-start their local plan review (based on a plan adopted in 2014 which doesn’t have any housing provision target because it was expunged from the plan by the High Court). Their earlier draft of 2016 put forward a contribution of 2,000 to address Birmingham’s needs but without any justification and with fairly universal derision from other HMA authorities. That wasn’t addressed in their supplementary consultation in early 2019 and we await their LDS to confirm the timetable for submission during 2020. Remember, they had two GL Hearn growth locations identified within the district: to the south of the airport/JLR and around Balsall Common.
• Lichfield has commenced a local plan review with intent to consider up to 4,500 above its own needs although over a plan period running to 2040. Whether this offer is to meet the 2031 shortfall or go some way to address the apparent 2036 shortfall is unclear. They hope to reach adoption by 2022 (by which time the BDP will need to be reviewed anyway). The GL Hearn study had identified potential rail-based settlement growth around Shenstone, east of Lichfield and north of Tamworth.
• South Staffs, which wraps around much of the Black Country, is offering to provide up to 4,000 above their own needs by 2037 with an aim to adopt by 2022. Again, it is unclear how much of this is intended to address the Birmingham shortfall to 2031 or how much the Black Country shortfall which is to be clarified to 2036 and beyond. GL Hearn recommended growth locations north of Wolverhampton and north of Penkridge.
• Cannock Chase, again to the north of the Black Country, is considering between 500-2,500 towards the shortfall by 2036, although with no GL Hearn recommended growth locations.

The Birmingham AMR states that the Black Country and Bromsgrove plan reviews are underway but not at a stage to make any contribution (and Bromsgrove has already helped out Redditch). In fact, since their own review started, the Black Country authorities have been pretty clear that they have their own shortfall to contend with. It was initially referenced as 22,000 by 2036 and in their most recent Urban Capacity Study published in December [BCP-summary-urban-capacity.pdf], the figure has crept up to over 26,000 by 2038. This is not news and has always seemed to me to a strange “shortfall within a shortfall”. If PBA were reporting the overall shortfall to 2031 in 2015 as 37,500 of which “90% was attributable to Birmingham”, I could never quite understand how the Black Country had a shortfall of significant proportions albeit over a slightly longer timeframe.

This non-sequitur is repeated in the Birmingham AMR, where it states that there is up to 20,730 being offered by HMA authorities towards the ‘shortfall’, whilst noting the (previous) 22,000 shortfall figure claimed by the Black Country authorities, but there is no recognition that this more than wipes out the total contributions from other authorities. Where does this leave the overall Greater Birmingham and Black Country HMA shortfall? Or are we seeing the start of the breakdown?

The Confusion Continues

On top of all this, we have the WMCA Housing Deal, struck by the Mayor in 2018, which is promising to deliver 215,000 homes across a slightly different geography (including for instance Telford and Shropshire) and timescale (from 2017-31) and which is not being monitored or reported anywhere as far as I can see. Lots of good stuff is happening and much of it is bringing forward longstanding brownfield sites, so this has to be welcomed, but its devilishly difficult to work out what is actually going on.

What I am sensing is that the shortfall is shifting across the sub-region. It started the decade as a Birmingham phenomenon which has gradually been whittled away and will end it as a Black Country problem (although one that was always there). Having said that, the Mayor has come out strongly against the Black Country’s Urban Capacity Review as reported only this week in the Express and Star – Andy Street article. We apparently need no Green Belt anywhere anytime. The shortfall has gone!

In reality, as opposed to political expediency given there is a Mayoral election in May, the shifting shortfall will push responsibility for resolving it from the politically reluctant authorities in the south and east towards the more willing contributors in the north and west. It feels like regional strategy is repeating itself, as I recall the mantra from the early 90s of avoiding the overheated south-east of the region by regenerating the north-west. It’s Telford’s time again (and possibly Shropshire’s). Worth a look if you aren’t doing already.

As I said earlier, this isn’t a problem in the short term as housing delivery is up and the Mayor’s brownfield-first policy is generating results and I applaud that. The Mayoral election in May 2020 means the message is going to be pressed home strongly and I’m not sure any of the challengers will give voice to a radically different strategy, as evidenced by the General Election manifestos of all the main parties. Brownfield First is a strong principle. Delivering housing in areas of greatest need and longest neglect is unarguable. Capitalising on investment in new transport infrastructure is the right strategic approach. However, I am not convinced we are going to have the right homes being built in the right locations through the 2020s, and risk extending commuting distances if we continue to encourage higher value housing to locations beyond the Green Belt whilst throttling the metropolitan area where many jobs remain and will be created.

Back to Birmingham

My consistent point about the Birmingham shortfall has been that it wasn’t ‘backloaded’ to begin with. The city has only met a proportion of its Objectively Assessed Needs, as measured against its 51,100 supply, since 2011 and has failed for almost half the plan period to bring into effect the allocation of land outside the city to meet the shortfall. The fact is that Policy TP47 has no five-year-supply in other districts to monitor yet, as the AMR admits there are no other LPAs currently providing for Birmingham’s needs.

The city’s own housing delivery is currently looking good as its AMR reports, with over 18,000 homes built between 2011-19 against a requirement of just under 17,000 (based on the 51,000 not the 89,000 need of course).

There is a five year supply of 6.6 years (almost 20,000 capacity) and the SHLAA currently identifies capacity including windfalls at almost 65,000 for the plan period. This is 14,000 more than the 51,000 in the BDP, clearly significant at a regional level as it equates to the entire housing requirement of an average sized district.

Breaking down the delivery of homes in Birmingham over the last eight years shows:

• 30% have been one-bed against a SHMA requirement of 14.6% and
• only 14.9% have been 4+ bed compared to a need for 28.1%.

Looking at dwelling types, 48% of all completions have been houses as opposed to 52% apartments, but this has shifted markedly from 2013/14 when it was 76% houses to 2018/19 when it was 81% apartments.

Densities have also increased over time with an average of 190dph in the city centre (against BDP policy of 100), around 60dph in areas well served by public transport (versus BDP policy of 50), and just under the target of 40dph for development elsewhere in the city.

This tells a story of city centre apartments now driving housing delivery in Birmingham and roughly providing twice as many one-beds and half as many four-beds as the SHMA says is needed. And the pipeline continues to be fed. In addition to 6,500 completions in the city centre since 2011, 5,800 are under construction, another 5,800 have planning permission and there is capacity for 12,800 more on BDP allocations.

This is great news for the city centre and we are seeing some really exciting new developments in urban living, but this is another side of the numbers game. As Philip Barnes of Barratts has said [https://wordpress.com/read/blogs/38154662/posts/1225], some local authorities are using the boom in urban living to ignore the housing needs of aspirational families, as sites for medium and lower density housing are not coming forward. Again, this is storing up problems, not just in the West Midlands.

What next?

So to finish off what has been a longer blog than usual, what might happen next?

There are good examples of strategic planning across England (excellently reported by Catriona Riddell including here: https://www.planningresource.co.uk/article/1665083/five-ways-spatial-planning-changed-1990s-catriona-riddell) but none in the West Midlands. Ironically, the only example is the Black Country Joint Core Strategy which was the result of the RSS.

There is no appetite and no political will to either seek strategic planning powers or to work more collaboratively. Officers have done their best to make it look better than it is, but five years on from the BDP examination, the Birmingham shortfall has not been “addressed” as the Inspector was led to believe. It might have gone away or been reinvented as something else but not in any planned way.

The authorities which have done something positive are the same ones which offered back then (and credit to them). A new wave of local plan reviews promises something for the long term, but we are now looking ahead to 2036 and in some cases to 2040 whilst still unclear exactly how we are getting to 2031. If GL Hearn are anywhere near right, the next five years after 2031 will bring an HMA shortfall of around 60,000 so we may be looking at 100,000 by 2040. Planning for that should be starting now.

A multi-authority level of agreement is not in prospect so the best we can expect is more localised MOUs perhaps similar to that achieved in Coventry and Warwickshire to underpin their local plans. As it is, they are now embarking on a round of joint evidence base gathering and may yet do a Single Spatial Strategy for six authorities. Might something similar emerge around the Black Country and its northern and western neighbours? With new Conservative MPs across the sub-region, they may decide to act in unison to get a better deal from Government. Will the Metro Mayor hold things together and, if Andy Street retains the role, build on his connections with Downing Street?

And might we get to the point one day where strategic planning tackles housing, employment and infrastructure together, because this blog has all been about the housing shortfall? There is a wholly separate strand of activity around the Local Industrial Strategy, the Strategic Economic Plans of the WMCA and LEPs, and the failure of local plans to adequately address the need for strategic employment sites which deserves, and will get, a blog of its own in due course.

It reminds me that the WMCA Land Commission report of February 2017 made three recommendations that still sit there unanswered – the need for a spatial planning framework which does not exist, a strategic review of the Green Belt which has never happened, and a vision for the sub-region with ‘unity of purpose’. Those would be a good list to start the next decade with.

Happy new decade!