Black Country Core Strategy Issue and Option Report

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.

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.

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.

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.

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.