Submission to Local Plans Expert Group

Here's a copy of my submission. Do you agree/ disagree? Any feedback welcome.


Submission to Local Plans Expert Group


Introduction


I am making this submission on the basis of my experience in the development plan system especially working on strategic planning issues.

I managed the Group preparing the Birmingham Unitary Development Plan in 1993 and 2005 and the current Birmingham Development Plan until I left the Council in 2014. On the latter, I was closely involved in dealing with the Duty to Co-operate and in taking forward a Strategic Spatial Plan to cover the Grater Birmingham and Solihull Local Enterprise Partnership area – as a key document to provide the spatial component for the LEP’s Economic Plan.

I am currently working with Luton Borough Council as Strategic Planning Manager concentrating on taking forward the Local Plan. As in Birmingham, the cross boundary issues facing Luton are substantial.

I was also involved for many years with the work on the Regional Spatial Strategy for the West Midlands leading the work on employment land issues. Most notably this resulted in the identification of a strategic location which has provided the site for the new Jaguar Land Rover Engine Plant at i54 to the north of Wolverhampton.

Over the past two years, I have also been actively involved with the West Midlands Futures Network, a voluntary group of those who consider there is an urgent and continuing need for effective strategic planning. A copy of the group’s Manifesto setting out the case for strategic planning is appended.

To start my response, I have set out some of the principles of development planning:

1. Development plans provide direction and vision to manage and encourage change in a locality. They need to reflect the characteristics of their locality but crucially the community they serve.

2. When reference is made to community there is a need to be careful that plans address the needs of the future community and do not dwell unduly on those of the existing community. To do the latter is common but this tends to build inertia into the planning process.

3. Unlike most other plans, strategies or programmes, development plans are based on integration across all policy areas. This adds complexity but it also, if plans are prepared effectively, leads to higher growth, better quality of living and greater efficiency.

4. It is important that development plans remain relevant and robust. A tendency towards too much detail and inflexibility should be resisted since it adds time and expense to the plan preparation process and results in a plan that becomes out-of-date shortly after completion.

5. Development plans should be seen as the most pro-active part of the planning system. They should not be seen as a brake on the economy. Instead, they should be seen as vehicles for the delivery of growth and development and, as such, should be regarded as an integral part of a productive economy.

6. Planning policy and strategic planning have been subject to severe cutbacks in many local authorities yet it is a function that should be properly resourced. Government should therefore incentivise this by earmarking some funding, say from New Homes Bonus, to achieve this. In fact common sense suggests that, by encouraging more development and investment, such resources effectively should be seen as ‘invest to save’.

7. Any review of local plans needs to ask if the ‘asks’ of the system are appropriate and reasonable. Over the years, the system has become far more process-oriented and required to cover more and more things. An example here would be the way in which the Environment Agency effectively shifts responsibility for its activities onto local planning authorities (LPA). Another example is the difficulties LPAs find themselves with seemingly ever-shifting Government directives on dealing with Gypsies and Travellers.

8. Finally, development planning needs to effectively deal with cross-boundary issues. The Duty to Co-operate is a sub-optimal replacement of former Regional Spatial Strategies. It would be interesting to see a genuine cost comparison of strategic planning under the Duty to Co-operate. My guess is it is not only far more expensive (given the scale of time and resources involved in examining issues at numerous public examinations and inquiries) but also significantly less effective! The Duty to Co-operate is also seen as an Achilles heel of the system that many participants seek to exploit.

The remainder of this note is ordered under the specific questions raised in the consultation.

a. Content of local plans (including requirements of the NPPF, overlap with the NPPF, ditto re. the NPPG, length, preambles, template policies, spatial detail, plan period, one plan or several, relationship with local guidance etc. – including good and bad examples)

Length – Plans should be as short as reasonably practicable. They should also be easy to read and understood by everyone. In short they should tell a story about their locality reflecting on the past and providing a compelling case for the scale location and quality of future growth and development.

Coverage – there is a tendency for plans to focus on a few key issues, especially the level of new housing provision. In my experience there is need for plans to take a much more balanced view, for example, also looking at the needs of other uses, including those that might be considered less valuable or attractive such as ‘bad neighbour’ uses. Broadly speaking the planning system should cater for all development needs. In practice some ‘fall between the cracks’. A example here would be the failure of the planning system to deal effectively with motorsport venues, allowing many venues to be lost through redevelopment to higher value uses with little, if any pro-active planning.

Template policies – in my experience these tend to be favoured by some consultees looking across many development plans. One the one hand it enables such organisations to participate in the planning process across many authorities but on the other could be seen as ineffective and failing to provide bespoke advice to a particular locality. They may have a role in sharing best-practice but it is important they are not given undue status.

Spatial detail – too much detail is risky for development planning for the reasons outlined above but we need to recognise that a level of detail most appropriate to a particular area should be the way to go.
It is obvious that an approach to a local plan in Birmingham must be different to a rural area. One thing that should be a pre-requisite, however, is that the appropriate level of detail should be finalised having taken full account of any cross-boundary matters having been satisfactorily resolved. Without this it is possible for a local authority to spend a lot of time on the detail when the really important matters go unresolved.

Plan period – this is interesting. It could be argued that the tendency of the current system to look forward around 15 years encourages compromise, partial solutions. Taking a longer perspective could enable more radical, more effective solutions. There could be significant benefits from this if the concentration of growth in certain areas could help ensure the proper provision of supporting infrastructure and at the same time reduce pressures on other areas.

One plan – a single plan has its attractions but in reality a suite of documents, all complementary can be just as – if not more – effective, be more responsive and practical in terms of resource and expertise to prepare them. There is obviously scope for LPAs to concentrate on the more strategic elements and provide the basic information and tools for Neighbourhood Planning. A related question might be on the status of the plans and the current system which requires the allocation of sites only in development plan documents. In practice it would be much quicker and simpler if Supplementary Planning Documents were able to do this, even if those documents are recognised as having a lesser status. I participated in a Local development Framework Sounding Board and unsuccessfully argued the same point before the elements of the current system were put into place. It would be good to see the Expert Group at least reconsidering this point.



b. Local plan preparation process – could procedures be changed to provide better and quicker plan preparation? This would include matters such as the terms and flexibility of existing Regulations, the appropriateness of statutory requirements, available ‘best practice’ guides, irreducible requirements and can these be changed, scope for active case management, tests of soundness, the terms and implications of the duty to co-operate, the appropriateness of early review, modifying plans post submission, the examination process, powers of intervention, the importance of transition in any change etc.)

Radical Change? If the Expert Group is considering more radical options why not at least consider development planning with differing levels of certainty. If a plan were prepared, subjected to consultation and amended as seen appropriate by the LPA then could this not be initially adopted as SPD and be used as the basis for development management? Only in the event of a planning application within certain categories (say above a size threshold, within green belt or where there is a threshold of objection) would there really be an issue and in these circumstances couldn’t those decisions potentially be removed from the LPA? That would then give the LPA a strong incentive to take the plan forward to full development plan status, the reward being local control over the planning decisions. But the other advantage is that LPAs could more easily and quickly get plans with an improved level of status to be in-place. A change to the system on these lines could significantly improve the speed and responsiveness of the system.

Soundness – one of the characteristics of old-style local plans and Unitary Development Plans was that Public Local Inquiries concentrated on objections made to a plan and not on the more amorphous concept of soundness. The advantage of the old system was that if a LPA prepared a plan with a weak evidence base then it would be ‘found out’ through the inquiry process and changes


would be recommended to the plan by the Inspector. The LPA would have the scope to add to the evidence – on a tailored basis - to justify its position as part of that process. The current system is inflexible and requires a full range of evidence to be prepared across the board. This completely ignores Pareto’s principle adding complexity, cost and delay.

The Duty to Co-operate – despite a lot of effort by many practitioners this is clearly not working as effectively as it should and there is a stark contrast between the need for it to be effective and localism. Greater clarity is required and maybe there should be incentivisation or penalties to LPAs that do not participate fully and effectively. Most of my comments on the Duty are included in the next section (c).

Early review – this is the approach that Birmingham City Council decided to take in its dealings with adjoining authorities on its housing shortfall. The position was that plans into which much effort had been invested should not be wrecked subject to a commitment to participation in joint technical studies and where the outcome justified it to agree to the early review of the local plan.

Modifications post-submission or through the Examination process. In principle these techniques should be encouraged subject to provisos. First, that there should be full and effective consultation on the changes as they emerge through these processes and second that a situation if many changes are made, or the changes are on major issues that can put into question the overall quality of the plan that has been put forward. In other words there have to be limitations to this flexibility.



c. Agreeing strategic requirements (including cross boundary requirements) – this could include the role of SHMAs, the appropriateness of evidence requirements and methods for calculating objectively assessed need, the potential for strategic plans, two stage plans, dispute resolution, the role of intervention, striking the relevant balance, etc.

Strategic requirements - at present there is little incentive to encourage a sceptical LPA to effectively participate and really solve cross-boundary matters. It is easy to understand this because the issues are complex, controversial and especially tricky for some local politicians to handle. Effective strategic planning arrangements can be the only way to deal with this situation, a matter that has exercised the thinking of the West Midlands Futures Network in it Manifesto (appended).



It seems unlikely we will see a return to regional planning but commonsense suggests that some form of sub-regional planning at least is required. A pragmatic solution might be to suggest that the preparation of strategic spatial plans either by Combined Authorities (where they exist) or by LPAs grouped by Local Enterprise Partnership areas. As a minimum these plans should be required to determine the level and distribution of growth between authority areas and possibly broad distribution within authority areas (such as split between main settlements and a brownfield/greenfield target). Such plans would preferably be prepared and agreed on a voluntary basis but in the event this does not happen then a planning conference, independently chaired should be held with the outcome being the hi-level spatial plan. Some sort of strategic arrangements of this nature would also help provide some direction for more effective governance and also help to address the situation in many areas where local plan preparation is not synchronised.

Planning at the sub-regional level would also enable the scope of joint technical studies to be agreed hopefully leading to some efficiencies. It might be argued that Combined Authority proposals will

see this all this to happen but this is not necessarily the case since in the West Midlands, for example, the current proposals do not cover strategic land use planning with the emerging proposals appearing dominated by transport matters.

In terms of resourcing there is a powerful argument that this strategic-level work could and should be funded through top-slicing of New Homes Bonus.

Objective assessment of need – difficulties arise due to several interpretations and challenges almost as soon as they are prepared. There is always another source of data around the corner and there is the risk of inconsistent approaches and double-counting . Job growth is now seems to be afforded much weight in the assessment of housing needs. Is this really appropriate or, in some circumstances at least, does this hide an over-allocation of employment land?

Housing ‘overspill’ – perhaps some guidance on dealing with overspill would help address the risks of adverse environmental / economic consequences.



d. Implementation (to look beyond technical issues to consider any other impediments to comprehensive local plan coverage – this could include financial or behavioural constraints or practical difficulties etc.; in addition this includes identifying best practice, lessons from joint working but also potential measures that could help to ensure timely local plan coverage).

Infrastructure - many responses to growth proposals highlight that the implications of growth for supporting infrastructure are inadequately considered. It is often difficult to really argue the point. There does appear to be a disconnect between investment programmes and growth and an inflexibility to change things. If we are serious about growth then surely the principle must be that the areas that are taking the growth should also be prioritised for the investment in supporting infrastructure. It should be accepted that existing schemes could, as a consequence be downgraded. One option might be to ensure that the appropriate bodies and investment programme are required to take account of what development plans say. In Birmingham, the Unitary Development Plan adopted in 1993 included proposals for development of local rail which have not been implemented even now and over many of the intervening years the proposals were not supported by the Local Transport Authority even though the proposals remained in the plan.



e. Observations – thoughts or relevant experience about how the system is working and the need for change;

I have included a number of observations above which I will not repeat.

Over my career I have experienced a planning system with different balances between what is statutory as opposed to non statutory. In my experience the value of partnership working in a non-statutory setting can exceed that of statutory or more coercive approaches. Maybe the time has come for a greater emphasis on voluntary working but to accept this needs to be properly funded and incentivised. If the local plans are not sorted when that support is in-place then some form of intervention might be appropriate.


f. Other – what other measures should the Group consider that might assist it to make recommendations which would contribute towards making local plan making more efficient and


effective?



Example 1: The requirements for Sustainability Appraisal appear overly onerous, encouraging a mass of largely impenetrable documentation. Such requirements should be simplified and made more proportionate and effective for example using a straightforward litmus-type test to identify if policies and proposals support or go against the grain of the plan’s approach. This should easily support identification of appropriate mitigation.

Example 2: The Environment Agency should be required to support LPAs in developing their development plans rather than the agency effectively requiring LPAs to do their job.



One final thought. In the era on online working has the time come to consider how local plans could be prepared and then maintained on an ongoing basis on the internet, thus becoming more frequently updated. This style of working has been adopted in relation to the NPPF/NPPG. Further thought on this might be warranted and safeguards to enable proper consultation would be required but this could enable development plans to be more responsive and ‘live’.

22 October 2015
David Carter BSc MSc MRTPI
D Carter Consulting Limited
Email: contact@dcarterconsulting.com or rollingstart@yahoo.com
Tel: 07795087173
Web: www.dcarterconsulting.com  

FNWM at MEF's conference in Stoke

On Friday 12 June I joined David Thew and Mark Middleton to help facilitate a workshop as part of the Midlands Economic Forum's conference on Future Connections: infrastructures for the future economy at the Britannia Stadium in Stoke-on-Trent. There was an interesting discussion in response to our presentation (see below) and some exciting new  connections made.

New Housing, New Government; What can we expect? West Midlands RTPI Seminar

I was asked to speak at this event held in Stratford upon Avon on Tuesday 12 May 2015.

The following images show my presentation which, hopefully, provided some food for thought!

 

CLICK HERE for a pdf version.

 

CLICK HERE to access my speaker notes

 

In answer to questions I also suggested that several things could be inferred from my presentation. Put together these included:
1. That Green Belt and Open Countryside policies should be combined.

2. That the key gaps and green wedges penetrating built-up areas should be identified.

3. To consider the use of 'White Land' or Areas of Restraint to provide the flexibility and certainty for long term growth.

4. By long term this should look ahead for 40 maybe 50 years. This would provide the coherent and once in a lifetime recalibration of Green Belt.

5. The purposes of Green Belt should be refreshed to take account of current and anticipated circumstances. This especially applies in relation to assisting urban regeneration. This refresh should take account of the need to secure a sustainable pattern of development.

6. The preferred approach might involve a limited number of growth points including a mix of regeneration and other schemes. This would enable appropriate infrastructure to be provided and enable placemaking as well as reducing pressures for growth in remaining areas.

 

 

Futures Network West Midlands

Here is the url to the FNWM website: http://futuresnetworkwestmidlands.co.uk

This website explains all you need to know about network and how to become involved. You will also find all the FNWM publications including its recent manifesto.

Birmingham Development Plan Duty to Co-operate Session

Here are a few observations from the examination hearing session held on Thursday 30 October.

The good

Lots of work over the past couple of years within the GBSLEP is paying off. All of the LPAs present very supportive of joint working and in their commitment to carry forward local plan reviews where necessary.

It was also good to see the City Council both recognise that the outcome of the strategic housing study could have implications for an early review of the Birmingham Development Plan and also to see a strong and continuing commitment from the City Council to the Spatial Plan for Recovery and Growth.

The not so good

The continuing delays to the GBSEP strategic housing study are doing no favours for anyone. There really is a need to push this forward and the delaying tactics by some of the ‘related authorities’* to be overridden and recent correspondence before the Inspector suggests this is recognised. 

The fact that the GBSLEP and Black Country have written into the brief that any final strategy coming from the completed study which relies on capacity in LAs outside their areas will require agreement is conveniently (or maybe deliberately) ignored by those that might be affected.  Not acceptable.

*authorities that can be regarded as forming part of the wider housing market area but lying beyond the GBSLEP and Black Country.

And the rest

Staffordshire County Council who were, I believe, the only local authority to claim failure of the duty to co-operate in their representations did not appear in this session although they had previously attended an earlier session when the approach to minerals and waste had been discussed. The effect was that the discussion on compliance with the duty to co-operate focused only on housing matters. 

One of the main reasons for preparing the duty to co-operate agreements that did not explicitly come out in the discussion was to ensure that the full range of strategic matters was covered.

There were fewer lawyers at the table representing participants (c.f. the reopened Lichfield hearing, for example) but an increasing and worrying trend appears to be lawyers taking over the role that should be the domain of planners. At the duty to co-operate session Messrs Young and Richards tried, in effect, to construct legal arguments that a failure of the Birmingham Development Plan and by implication all local plans across the peace was the best way forward. That is the law they argue. If that is the case then the surely the law is …..! What the session again demonstrated is that the LPAs in the GBSLEP are trying their best to make this planning system work. The authorities can’t be blamed for the deficiencies of the system.

In relation to the strategic housing study there remains some confusion between what should be a ‘policy off’ technical study and the close involvement of Chief Executives and Members risking ‘policy on’ too early. While understandable, the effect is a contributing factor to the delay.

And finally ...

I was not sure where to put this one but it was a surprise to learn that the Black Country did not anticipate adopting a review of their Joint Core Strategy until 2020 and this followed withdrawal of the earlier ‘offer’ of 3100 spare dwelling capacity to help meet Birmingham’s needs. How can such a timescale be justified when the adopted Joint Core Strategy is neither based on an objective assessment of housing need nor does it consider the significance of growth pressures in Birmingham, part of the same wider HMA? 

Tripwire: September/ October 2014 - Long live strategic planning by David Carter

I was asked to write a short article for the RTPI's newsletter reflecting on my experience of Strategic planning in the West Midlands. Here is a reproduction of this article.

On 29 August 2014, I left Birmingham City Council for the last time. I had been there since 1986 and before that had spells at West Midlands County Council (WMCC) and Wolverhampton MBC. My first job was as a Trainee Planner experiencing roles in all the key areas of planning including development control. A brief period at Wolverhampton in Economic Development was invaluable in giving me an understanding of development viability and implementation. 

Most of my career, however, has been working on strategic planning and during this time the planning system has been altered significantly on several occasions. I thought it would be interesting in this piece to reflect on some of my experience. 

It’s all about structure 

Structure Planning was the name of the game in the 1970’s and, in fairness, these plans – which had 100% coverage – are fondly remembered. Whilst working on the West Midlands County Structure Plan took a fair proportion of my time, what I remember most at both WMCC and the City Council were the Examinations-in-Public for the shire county structure plans. It was through these that many of my networking contacts were initially made and these have stood the test of time. 

The early ones were supporting Alan Johnston who was to go on to become the County Planner at Leicestershire CC. I learned several really important things at these EIPs. The application of tactical thinking and presenting a coherent case were really important. Preparation is the key to achieving both of these. Another key lesson was in actually addressing the questions put by the Panel and adapting the arguments accordingly. While this seems pretty commonsense stuff it was (and remains) surprising how many participants did not do this at such events! Over the years the tool I used was a copious supply of post-it notes - the easiest way to remember key points, order them sensibly and effectively produce speeches very quickly. 

At the time of structure plans of course we also had local plans. My personal experience was working on the Aldridge- Brownhills Local Plan but overall this era of local planning was hardly blazed in glory. Many local plans took far too long to produce and were overly detailed and inflexible. 

All change 

Abolition of the Metropolitan Counties in 1986 brought in Unitary Development Plans coupled with a new type of strategic planning through new ‘Strategic Planning Guidance’. This was to prove effective in bringing together the unitary authorities and shire counties, facilitated by a Planning Conference, to ensure effective cross boundary planning. This process enabled the initial round of UDP’s to be produced, including the Birmingham Plan. 

There few rules and regulations governing the new types of Plans and this presented the opportunity to produce the sort of document we wanted if we were quick enough. Regrettably, subsequent revisions to the planning system have introduced all manner of guidance and good practice to tell us how we should be doing things. 

The Birmingham Plan (UDP) was the subject of Public Local Inquiry, but the best thing about this process – in my view – was that the inquiry was into objections to the plan so the LPA was able to marshal the evidence needed to make the case stick. There was not the current vogue to examine ‘soundness’ , which in my view, places too much power in the hands of PINS - or the requirement that all the evidence to support the plan has to be in-place, up-front. 

Stand up and be counted 

In the mid-1990’s I experienced my first big Call-in inquiry into the extension of the Merry Hill shopping centre. I helped pull together a consortium of c30 local authorities and private companies to fight the proposals. The inquiry lasted around 6 weeks and I remember my biggest worry (apart from the anticipated cross-examination!) was clocking up of various consultant’s and legal fees without an agreed budget to cover them. Fortunately everyone chipped-in so the bills got paid. However, in career terms working with Martin Kingston QC for the duration was invaluable and helped set me up for all the subsequent inquiries and examinations I would encounter. The outcome helped instil the confidence to enable the redevelopment of Bullring in Birmingham as well significant rejuvenation and investment in a host of other town centres – such as Walsall and West Bromwich. Other memories from that inquiry include John Taylor QC’s chauffeur-driven Roller and one of the late Sir Peter Hall’s few forays into the West Midlands on behalf of Chelsfield, the centre owners. 

Here we go again 

UDPs were replaced in 2004 by the new Local Development Frameworks although in Birmingham we completed the Alterations to the UDP in 2005. The complexity of the LDF system proved to be challenging but it did have its advantages. In a complex authority like Birmingham the preparation of a single plan comprehensively covering strategic and local aspects in one go was demanding to say the least, so the concept of the suite of documents addressing the city as a whole – through the Core Strategy – and neighbourhoods and localities or within particular policy areas was and remains attractive. I say it remains the case, because for all the bluster by the current Government, the essential characteristics of the LDF stay in-place albeit with a greater emphasis on production of a single local plan. 

In late 2010 we produced a draft Core Strategy which, with the benefit of hindsight, could and possibly should have been pushed through to submission and adoption in the light of delays to the revocation of the Regional Spatial Strategy (RSS). It is, of course, the revocation of the RSS’s that is the ‘Achilles heel’ of the development planning system. We now have to rely on the tricky cross-boundary strategic stuff being sorted out and then taken forward in the district-level plan. Initially, the RSS’s may have had few friends, but in the West Midlands the Regional Plan was responsible for heralding the urban renaissance approach on the back of the Lord Rogers Task Force. It was a successful in that it ensured effective cross-boundary planning across 38 local authorities. Policy-led planning was then the vogue. 

Pickled, or maybe not? 

This brings me up to date and to the Duty to Co-operate (DtC) which was introduced to fill the strategic gap left by the RSS revocation and occurred in parallel with the establishment of the new LEPs. In the West Midlands I tried to encourage discussions at regional, metropolitan and Greater Birmingham and Solihull Local Enterprise Partnership (GBSLEP) levels early on, based on the premise that working together should be less risky, more effective and more efficient than relying on bi-lateral liaison. This particularly applies in the West Midlands where so many authorities need to be involved. To my mind, since the LEPs were the new show in town it was logical they should be a focus for strategic spatial planning activity. The Black CountyCore Strategy which was in a separate LEP would not be reviewed until 2016 so a strategic spatial plan needed to be taken forward in the GBSLEP area. 

The emerging GBSLEP’s Strategic Plan for Recovery and Growth (SPRG) offered the most significant challenge and scope for innovative thinking for many years. Strategic planning capacity had already been drastically cut, the Regional Assembly’s capability had all but disappeared and in the City Council resources had been reduced by more than one-third. So how could we produce the new-style spatial plan? Essentially the answer was to bridge some of the lost capacity by directly involving our partners from other sectors, not just as a sounding board, but by asking them to lead some of the work. To some, the ‘loosening’ of local authority control might be regarded as a risk, but I saw it as a key strength because it engenders what I have described elsewhere as ‘collaborative responsibility’. 

One of my regrets in leaving my job is that I am unable to oversee the completion of the next stage of the SPRG, but make no mistake if this happens it will be a huge achievement which will demonstrate that the DtC can be made to work and is an approach that could almost certainly be adapted and adopted in other areas. 

The planning system: in need of an overhaul? 

If the GBSLEP fails to produce the second stage of the SPRG then the thorny issue of the scale and distribution of long term growth will remain unresolved. This will render the DtC as unworkable and the development planning system will need a fundamental overhaul. Perhaps of greater significance, however, would be that the economic potential and future quality of living in the West Midlands would be compromised. 

In approaching the DtC, whether in joint or bi-lateral discussions, my strategy has always been to try to provide leadership, since that is what I believe the largest local authority is expected to provide, but to do so in a way which is neither dominating nor insensitive to the views in the adjoining areas. It will be for others to judge whether I achieved this and time will tell whether the City Council continues to adopt this approach or if the nature of relations across the sub-region enter a new phase. 

The next step 

Throughout the second half of the c20th Birmingham’s population was in decline, a process that was at least partially driven by the post WW2 planning policies of decentralisation. This decline has now been reversed, no doubt assisted by the successes of urban renaissance strategies, which whilst critical, require a refresh in the light of significantly changing circumstances. In a period of rapid population growth in my view we should adopt a twin-track approach which continues with urban renaissance but also allows for significant growth elsewhere. 

My prescription would be to ‘go for growth’ but to concentrate this in a limited number of both brownfield and greenfield locations. This would allow for a selective review of green belt and also consider the creation of a new industrial or economic zone, or zones, close to the conurbation. Such an approach would take the pressure off most areas and provide a plan that unequivocally answers questions on the strategic direction of long term growth. Coupled to this would be a requirement that infrastructure investment should follow the growth leading to a rewriting of investment priorities. 

While strategic planning has been in the doldrums, it is beginning to make a return. The GBSLEP can see its value and it is interesting that the LEP’s Strategic Economic Plan’s Growth Deals make a welcome reference to need for positive planning being a pre-requisite for securing funds. 

Uncertainties over Governance remain an issue and there must be some hope that there might be a move towards a combined authority across the wider city region. The Leaders of the metropolitan districts have taken control of transport agenda but this really needs to be far better integrated across and on equal terms with other policy areas thus enabling West Midlands achieve its full potential.

Lichfield Local Plan - Re-opened Hearing

The morning session was all about Birmingham's housing needs and it turned out to be very interesting. The main issues remain the scale of Birmingham's housing shortfall and its distribution. Martin Kingston QC led the attack on two grounds. First, that the Lichfield Plan is unsound because of the absence of clear evidence of housing need and that this demonstrates that the Duty to Co-operate has not been effectively carried out. The second point is that the shortfall in Birmingham's need is current and it should not be shuffled until some later date. Adopting  the plan early could result in the incorrect strategy being adopted.

This position was criticised by others as scaremongering since the scale of the Birmingham shortfall remained uncertain and that, in effect, everyone was trying to cope with an inadequate planning system post-revocation of the Regional Spatial Strategy. The Inspector was keen to know what sort of scrutiny would take place on the Strategic Housing Needs Study.

In my view the answer - which was highlighted by the District Council - is really quite straightforward. The Strategic Housing Needs Study will inform the GBSLEP Spatial Plan that will propose the level and distribution of development. This is an informal process but it will be subject to scrutiny as part of local plan examinations. This may not be the ideal way forward but it represents the best shot at the moment.

Alternatives such as a conference of planning authorities with a binding outcome might be possible, and even desirable, but we have got some way  to go to achieve this.

10/10/14: As a postscript to this, one of the light hearted moments was when Martin Kingston asked just where was the Birmingham housing shortfall going to go? Mars he suggested, although one could ask on what objective assessment had he chosen this? What would be wrong with Venus?!