Policy Area D - The Black Country Centres

1. Meeting Housing Need

The research on which the housing need assessment is based is problematic in a number of areas, but two stand out.

Firstly, it has only this week been revealed that the West Midlands is one of just two areas in the country in which house price growth has been exceeded by wage growth since 2007. This calls into question a key plank of the argument for housing demand projections, namely that there is a strong supply and demand signal from the market. Clearly if there is a market signal at all it is the reverse - that supply is more than meeting demand. At best this calls the projections into question.

Second, since the data behind the projections was compiled the UK has voted to leave the EU. The government has made it clear that free movement of EU nationals will cease in 2019, and has recommitted to a target to reduce net migration to below 100,000. Net migration has already responded to the vote and shown a statistically significant downward shift. The Consultation reveals that the main pressure on housing in projections arises from migration. Regardless of political opinion on the issue, it is plain that the referendum vote makes the projections unsafe as any assumption about migration levels is now unsafe.

Ideally these two seismic shifts in the evidence base would call for a complete revision of the projections. Practically however this may not be realistic, but the projections must now be treated as unsafe as a basis for long term planning, and so long term plans must be mare adaptable and able to pull back from excessive provision, especially where this would destabilise markets or lead to perverse consequences such as unnecessary loss of green space and essential wildlife habitat.

In terms of where new housing should be built there are two issues. The first is the suggestion green belt land should be used. I will address that below. The second is the issue of release of employment land. It is self evident in many parts of the region that employment demands for land have shifted. Large numbers of industrial units lie vacant, usually long term. There is a surplus of office accommodation, often in entirely unsuitable locations, built largely because of the perverse incentives created by tax breaks under the Labour administration. Similarly retail units lie vacant long term, especially town centres, and to disastrous effect in smaller centres. These vacancies reflect medium to long term changes in the economy and in the location of economic activity. These changes are highly unlikely to reverse. Nobody is going to uninvent the internet and Amazon is not going to skulk off to save small town shopping. Indeed it is already encroaching on the market for convenience stores. These changes are permanent, and planning policy needs to accommodate them, respond to them and look forward to them accelerating.

With imagination employment land could provide more housing than is currently allowed for in the forecasts provided. Its unpopularity with developers is that it is often costlier to develop (and part of that cost is in addressing risk - costs are more likely to overrun on brownfield sites because unexpected conditions are more likely to be encountered) and is often in areas that a less desirable for housing, holding retail priced down.

The plan that emerges should address these issues by focusing on release of employment land where it is unrealistic to expect it to be needed in future and having an explicit policy that planning obligations should be used to ensure no more profit is available for developing green field sites. This could be done by increasing the affordable housing (nil grant) component of any green field development, insisting that all such developments are carried out open book or in extremis in only releasing green field sites for affordable housing. No green belt land should be released under any circumstances for anything other than affordable housing (this is a policy successfully used for all land not previously developed in places like the Lake District).

3. Retail, leisure and commercial development have all changed in recent years, while planning has not caught up. Planning is trapped in an ideological nostalgia for a world that is found only in grainy old movies and early TV shows. Out of town retail is more popular that town retail - in part because it is easier to access given traffic and onerous parking restrictions. Out of town leisure offer opportunities that town centre cannot. And for many commercial activities out of town location make more sense than town centre ones. Who, for instance, would put a distribution hub in a town. The focus of such development on town centres is absurd, because the market response is simply to not develop at all, leaving dead and decaying towns and an air of quiet and desperate desolation. Planning should respond to the modern economy, not seek to change it. An excellent example of how damaging poor planning policy can be is in the policies of the 1970s to preserve factory land use by banning development of offices on it. This took place in a number of declining industrial areas. The result was perverse. Modern factories had come to require offices collocated with production, as modern equipment shrank the production footprint but required on site administration, and cost saving meant it was then more sensible to also collocate roles such as administration, sales and marketing. Planning policy forbade this, and so factories did not modernise - they closed and moved.

4. Parts of the Black Country are very poorly served by parks, and the cycling infrastructure in the region is utterly woeful. Manchester, for instance, by contrast now has an officer in charge of developing cycling routes and promoting cycling, and he is well funded. It is experimenting with measure such as slugs in the road to separate drivers from cyclists. Access to countryside and nature are also vital in improving the health of residents in a region that contains some of the most deprived communities and where public health is an issue.

5. The green belt is an essential tool in preventing urban sprawl , protecting open space and providing for wildlife. It is also key in creating leisure spaces and improving public health. The National Planning Policy Framework makes it clear that the green belt should, in essence, be considered a permanent feature of planning policy and that its boundaries should only ever be reviewed as a very last resort. The only exceptions to this are redevelopment of previously developed sites, and development for infrastructure. The latter can be key to facilitating housing provision further afield in the countryside.

It is not clear that any of the planning pressure faced by the region reach the threshold required by the NPPF for revision of green belt boundaries.

However, there is a bigger risk at stake here.

Release of green belt land creates monumental financial incentives that are all but certain to lead to perverse outcomes. Green belt classification suppresses land values. In parts of the region - for instance Hagley or Stourbridge - it is not unreasonable to expect allocation of a greenbelt site to increase its value by 1000% or more. This is a truly colossal financial incentive for landowners (particularly speculators) to seek change to policy.

It also creates a perverse incentive for the local authorities themselves. Local authorities rely on Section 106 Agreements for much of their affordable housing provision, and the government now expects such provision to be delivered now without subsidy (nil grant). Sites where there is a very large planning gain create a greater scope for such agreements - there is more money to take off the table.
In addition developers often prefer green belt sites. Green field sites always come with the benefit that there is less risk because development costs can be more reliably forecast. Green belt sites come with the bonus that they are intrinsically in desirable areas, so easier to sell. They lend themselves to higher cost housing where though densities are lower they are made up for by far higher margins.

Release of the green belt is almost certain to cause green belt sites to come forward in preference to all other sites for housing. Once the policy is changed these applications will be impossible to resist because refusals will be readily be overturned on appeal. Even if the release is in principle staged the impact will be the same - prematurity is not considered by the Planning Inspectorate a legitimate reason to refuse consent on a site brought forward.

Planning policy cannot and should not ignore these incentives, especially those that impact on the authority with the power to grant consents.

In general I would contend that there is not a case at present to review the green belt boundaries. The housing demand projections are not safe, and changes to the shape of the economy mean that less and less employment land is likely to be required in future. There are still very substantial numbers of unoccupied shops, offices and industrial units and this is extremely unlikely to change in future.

However, any review of the boundaries should be subject to protection to address the issues outlined above. Some suggestions might be:

* No green belt land should be released in the first half of the period the plan covers - it is unsafe to do so. Green belt land should not be allocated and its protection should not be removed in the first instance - it should at worst be relegated to safeguarded land. This would allow its release later should the need arise but its reclassification as green belt otherwise.
* Only affordable housing should be built on the green belt. This removes most of the perverse incentives inherent in releasing green belt land while still addressing housing need. This includes the incentive on the local authority, because it cannot release large monetary values that would take pressure of housing budgets elsewhere at the expense the longer terms interest of the region and its people. It also ensures that high densities can be maintained to ensure as little land is released as possible.
* All greenbelt land should be objectively classified in terms of its amenity for leisure, heritage, wildlife, natural beauty and economic contribution. Only the very lowest scoring land should be considered for release. This classification should be strictly objective to prevent bias, and should ignore the land value that could be released.
* Any release should focus on existing settlements, and should be restricted to a small increase around the settlement boundary. This ensure minimal infrastructure costs - an externality that is never borne in full by the developer and land owner - and is more sustainable. Releasing a 100 m strip around a settlement with a 1 km diameter creates 163 acres of developable land, enough for over 3000 homes at 20 homes per acre. This is much less objectionable than the release of a site for an entire new settlement 1 km across.

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The role of public health is to improve the health of our residents, prevent risks to public health and reduce health inequalities to help people live longer and healthier lives.
Public health works to improve the health and wellbeing of our communities by identifying the risks that affect different people, in different places, at different stages of life, and finding the best way to minimise them.
By working with external agencies and local communities we aim to:
* Keep people well
* Prevent people that are showing the early signs of poor health from becoming ill
* Improve the quality of life of those affected by ill health
Walsall is one of the 20% most deprived districts/unitary authorities in England and about 30% (17,000) of children live in low income families. Life expectancy for both men and women is lower than the England average.
Life expectancy is 10.5 years lower for men and 6.4 years lower for women in the most deprived areas of Walsall than in the least deprived areas. In Year 6, 25.5% (833) of children are classified as obese, worse than the average for England. Levels of teenage pregnancy, GCSE attainment are worse than the England average. Estimated levels of adult obesity and physical activity are worse than the England average.

The Health Foundation states that as little as 10% of the population's health and wellbeing is linked to access to Health Care. The population's health and wellbeing is influenced by a wide range of other factors including housing, transport, employment, green space, where we live.
The review of the Black Country Core Strategy provides real opportunities to improve the health and wellbeing of the population of Walsall and the below details the response from Walsall Council Public Health to this consultation.
The review document is quite a difficult document to navigate. It is long, not very user friendly and includes a large amount of jargon. The document includes a lot of questions, many of which are quite specific and make it difficult to respond to directly. Our comments as such, while not directly answering all of these, do provide information that will cover more generally some of the questions in each of the sections to follow:
A. Health and Wellbeing
PHE Spatial Planning for Health, an evidence resource for planning and designing healthier places, 2017 identifies five aspects of the built and natural environment as the main characteristics that can be influenced by local planning policy:
* neighbourhood design
* housing
* healthier food
* natural and sustainable environment
* transport
Many of the above are covered within this strategy.
In addition, the health and wellbeing of the local population can also have a huge impact on a local area. From an economic perspective a healthy population will have a reduced need for acute and long term health and social care services and will also be more likely to contribute to an active workforce - with improved productivity and less sickness absence.
Health and Wellbeing is not considered as a separate policy in the current Black Country Core Strategy. Therefore, as part of this review health and wellbeing should be given its own policy and be embedded into the other strategy policies.
Moving forward we would like to see:
* Further acknowledgement of the wider determinants of health
* Needs assessments that give due consideration to the health needs and demographics of the local area for example, the local Joint Strategic Needs Assessment (JSNA)
* Design standards that promote healthy lifestyles and environments across the life course. This should include 'lifetime neighbourhoods; identification of an ideal high street retail offer; consideration to fully pedestrianzing town centres; sustainable transport and green infrastructure networks
* Ensure potential health impacts are considered through a Health Impact Assessment that includes involvement from the Public Health team

B. Creating Sustainable Communities in the Black Country
Housing should aim towards 'lifetime neighbourhoods'. Rather than have separate accessibility standards, housing needs to consider the life course approach and be accessible to people of all ages. It also needs to be broader than just accessibility, for example, well-connected and walkable and design standards that promote healthy lifestyles and environments, considering the Ten Principles of Active Design (2015): Activity for all; walkable Communities; Connected walking and cycling routes; co-location of community facilities; network of multifunctional open space; High quality streets and spaces; appropriate infrastructure; active buildings management , maintenance; monitoring & evaluation; activity, promotion and local champions.
The housing plan needs to take into account any additional demand on associated local amenities of education, health, transport and leisure facilities. The needs assessment should be sensitive to changing local demographics e.g. extended family occupancy, Eastern European migration and multiple occupancy, which has a particular disproportionate impact upon local faith specific schools and local parking/transport. The plan should attend to the needs of marginalised groups and their specific needs e.g. single adults, young people, people with disabilities and the frail and elderly as well as the hidden homeless. Attention should be given to the travellers/gypsy and showman plans and how this relates to the challenge of unauthorised encampments.
There is a plan to increase high density housing allocation in Walsall which is a particular challenge.
A Health Impact Assessment should be undertaken for any major housing developments with the support of Public Health.

C. The Black Country Economy
Setting targets for employment land is important however, this needs to have the balance particularly in terms of where the Greenbelt is located. For example, much of the Greenbelt is located in the East of the borough and is difficult to access for people in more deprived areas in the West. This is an opportunity to link with the transport policies to look at how this can be addressed.
Building social housing, as part of housing developments, planned for the Greenbelt could also help address this.
Priority sectors require highly trained staff. Does the local population have these skills or will the new development create 'commuter workers' from other areas who invest very little to the local economy? Unemployment in Walsall is higher than the England average. Training needs to be made available for the local population if local people are going to be able to access these jobs. This needs to include a focus on those from the most deprived areas of the borough.
Design considerations to promote healthy living also need to be considered in building developments.
D. The Black Country Centres
Whilst the importance of business rates is noted, there is a need for this to be balanced with a more mixed retail offer in Walsall town centre. PHE has found that hot food takeaways per 100,000 population in Walsall is higher than the England average, 93.7 per 100,000 compared to 78.3 per 100,000. In 2014 in Walsall, there were 654 licensed premises, which is 312 per 100,000 population (aged 18+) .
There is an opportunity to develop a profile of the retail offer currently available in Walsall for different categories of outlets, and what the ideal profile might be. The Royal Society of Public Health: Health on the High Street (2015) recommends measures to include:
* Local authorities to use planning powers to prevent the proliferation of betting shops, payday lenders and fast food outlets
* Public health criteria to be a condition of licensing for all types of businesses
* A limit of 5% of each type of business on a high street in order to avoid oversaturation and provide affordable choice.
Consideration should be given to fully pedestrian town centres with more sustainable forms of transport and design giving full consideration to accessibility for all e.g. people with disabilities. This will improve the health and wellbeing of the population and community safety.
Consideration should be given to community safety partnership data to avoid the adverse effects of town centre planning (proliferation of issues associated with substance misuse and street workers).
E. The Black Country Transport Network
There is strong evidence that motorised road transport provides clear benefits to society and improving the road networks across the region should provide wider economic benefits, however there is a potential cost to society (Public Health England, 2016 ). Increased car journeys can lead to a rise in the disease burden due to reduced physical activity and in addition it is expected that there will be an increase in road accidents, air pollution, noise and even reduced social cohesion and increased social isolation (Public Health England, 2016 ).
Walking and cycling should be the easiest and preferred option and the strategy should give consideration to inverting the hierarchy of transport e.g. walking, cycling, public transport car, share and private car. In doing so it is reflective that investment in walking and cycling infrastructure and behaviour change programmes can deliver low cost, high-value dividends for the transport system, the whole economy as well as individual benefits. In addition to support, an increase in the number of people walking and cycling, community protection and safety should be considered within the strategy. Small improvements can make a difference to encouraging people to be active including good street lighting or improved road crossings.
In relation to health inequalities those who live in more deprived areas tend to travel less than those in more affluent areas but bear the greatest burden of other peoples travel (Public Health England, 2015). It is important that the core strategy does not increase unfairness in communities (Sustainable Development Commission, 2011).
There is a requirement to ensure good access to services in the most sustainable way possible. It is important that vulnerable groups including individuals with disabilities and older people including those with dementia are consulted in the planning and development of their communities, as they can often provide local solutions that address areas of potential conflict. The street environment and transport interchanges need to be designed to meet the needs of individuals - including an interlinking of the different modes of transport.
The strategy details improvements to public transport but clarification is required that this means that there will be less cars on the road which should improve air quality and see a reduction in the number of accidents. Public transport needs to be easy and accessible for all to use but it is important that the costs are not passed down to the consumer as this could be a barrier to usage. It also needs to be incentivised to use or made easier and more accessible for all to use and more cost effective.
There is a growing body of evidence that is supportive of 20mph speed limits (Cairns, J et al 2014 ) and repeated national surveys (Department of Transport ) demonstrates that there is strong public support for these in residential streets.
Will the detailed improvement to freight access include measures around air quality/ noise quality? This should improve economic growth and the flow of lorries on the motorway.

Consideration should be given to;
* Closing streets to allow active play for children and for residents to come together as a community. Areas outside of the Black Country (Hackney etc) have successfully demonstrated this approach.

* Impact of electric car policies (new government legislation)

* Car Share

* Community infrastructure levy - reinvestment back into communities to encourage active participation.

The Black Country Environment
We support the principles of a Garden City and recommend that these are applied. These are: sustainable transport and green infrastructure networks; bio-diversity gains; carbon emission reductions and climate change resilience.
Design quality (including space and accessibility) needs to be considered as above, housing needs to consider the life course approach and be accessible to people of all ages.
Walsall canals are an asset which can be developed to enhance active travel within the area. We would not support the removal of the reference made to canal projects. We consider canals to be important in contributing to emotional health and wellbeing.
We support the proposed changes relating to open space, sport and recreation but we believe the policy needs additional criteria to be added to provide sufficient protection form development of open space.
It states that development that reduces open space will be resisted and that increases will be encouraged. We suggest the use of the Natural England Access to Natural Greenspace Standard to provide a quantifiable measure of the importance of particular areas of open space is required. Further clarification on what constitutes open space is needed as the policy does not specify publically accessible open space.
Air Quality
West Midlands has the poorest air quality outside of London.
We support the proposed changes. ENV08 also needs to be updated to reflect:
* West Midlands Pollution Group (which in-turn works within the framework of the Central England Environmental Protection Group).
* West Midlands Combined Authority (CA), (including Transport for West Midlands in respect of a range of issues that encompasses proposals for Clean Air Zones and the uptake of Low Emission / Ultra-Low Emission Vehicles).
Walsall Council additionally works specifically with the Black Country councils, and has produced the Black Country NO2 road emission concentrations model. This is a workstream that is subject to on-going review as long as resources permit, and an updated model output is scheduled to be released later this year. Other Black Country work streams include the Black Country Ultra-Low Emissions Vehicle Strategy and the Black Country Air Quality Supplementary Planning Document.