How remiss of me! Since I began working in the West Midlands I have been recording an annual collection of reflections on devolution and the Birmingham shortfall. Here we are towards the end of 2020 and I very nearly managed to miss the sixth instalment. If this is the first of these blogs that you have come across feel free to catch up via these links:·
December 2019 was a month that neatly encapsulates the issues at play in the West Midlands.
It was last December that Birmingham City Council’s (BCC) Cabinet considered the looming three year anniversary of the adoption of the Birmingham Development Plan (BDP). A review mechanism, readers of past blogs and followers of this whole, sorry farrago will know, was introduced late in the day into the BDP whereby BCC would review the Plan within three years of adoption (10 January 2017) if the expected rate of progress on distributing a 37,900 home shortfall was not being achieved. Progress was to be measured by the extent to which Birmingham’s neighbours committed to either review adopted plans or have regard to the shortfall in the preparation of new plans. It was concluded by BCC last December that “significant progress” was sufficient for this requirement to have been met and that a review should not be triggered. This was perhaps not an unsurprising conclusion for an organisation tasked with marking it’s own homework to come to.
Members were told that
Birmingham is leading on the Duty to Co-operate arrangements to ensure that progress is being made by other authorities in the Greater Birmingham and Black Country Housing Market Area (GBBCHMA) on local plan reviews to accommodate Birmingham’s unmet housing up to 2031. While not all relevant local authorities have submitted a revised local plan ‘providing an appropriate contribution towards Birmingham’s housing needs’ within the 3 years since the adoption of the BDP, it is clear that significant progress has been made by local authorities towards this. North Warwickshire submitted a revised local plan in 2018 which is currently in examination and local plan reviews are advanced in Solihull, Lichfield and Cannock Chase and underway in the Black Country, Bromsgrove and South Staffordshire. A HMA Housing Need and Land Supply Position Statement (September 2018) provides an update to earlier housing needs studies and timetables for plan reviews. This 2018 Position Statement suggested that the shortfall had fallen by 5,629 homes from the original 37,500. The Position Statement is currently being updated. This is likely to show further progress on addressing the shortfall.
December 2019 was also significant because it was by then that the Housing Package announced by the West Midlands Combined Authority (WMCA) with no little fanfare in March 2018 stated that ‘local plans within constituent and non-constituent authorities will be updated as necessary to deliver and accommodate 215,000 homes by 2030/31’. I shall return to that 215,000 figure below.
Finally, but not insignificantly, it was also in December 2019 that an Urban Capacity Review published as part of the emerging Black Country Plan evidence base identified a shortfall of approximately 27,000 homes up to 2038.
Yes in the story of the Birmingham shortfall, the parable that it is of modern strategic planning, or lack thereof, December 2019 is worthy of a special mention.
Let me, in modern day corporate parlance, ‘unpack that a little’ and consider where things are up to now.
The updated Position Statement, prepared on behalf of the fourteen LPAs that make up the GBBCHMA, revealed when it did finally emerge in September 2020 that the BDP’s shortfall had been whittled down to 2,597 homes, which, let’s face it, in the grand scheme of things, is practically nothing.
So that’s that.
There’s nothing more to see here.
The end of the story.
There will be no need for a blog next year.
Oh wait. Hang on a minute.
It is in the years beyond 2031, the Position Statement reveals, that there is now a shortfall across the HMA, but that is surely nothing to worry about now is it?
Well yes it is actually. Local plans across the HMA are now starting to look beyond 2031. Bromsgrove and Lichfield will look as far ahead as 2040 and contributions to the Black Country’s shortfall up to 2038 need to be factored into them.
It should also be pointed out that whilst the Statement claims, as Birmingham’s Cabinet was told, that “significant progress” has been made in reviewing local plans to the extent that LPAs both within and now outside the GBBCHMA have identified a contribution of between 16,890 and 19,490 homes to the shortfall, of these only North Warwickshire’s plan (a generous 3,790 home contribution) and Solihull’s plan (a miserly 2,105 home contribution) have reached Regulation 19 stage. Whilst North Warwickshire’s contribution is likely to be endorsed by an Inspector the validity of the remaining contributions remains untested.
Fans of strategic planning in the West Midlands will have to wait until the Solihull Examination for the weight and relevance of the Position Statement to be tested, but it is likely to be decreasingly limited on both counts over time focusing as it does on historic (and minimum) requirements that pre-date the standard method. It will be relevant to the plans at, or close to, Regulation 19 stage but even then it’s methodology and underlying assumptions will have to stand up to a lot of scrutiny.
Where then does that all leave the state of devolution and the Birmingham shortfall at the end of 2020 compared to the end of 2019? No further backwards is arguably the best that can be said, but what about the future?
There is a mayoral election to look forward to next year and since Liam Byrne is likely to give Andy Street more of a run for his money than Siôn Simon did last time out it can be expected that Mr Street will be playing up his ‘brownfield good, greenfield bad’ credentials for his edge-of-conurbation base.
During his first election campaign Mr Street spoke of the need for ‘a joined-up approach to housing across the West Midlands region’ and of ‘knocking heads together where there are obstacles’, but with the benefit of four years’ worth of experience in understanding just how difficult it is to join-up approaches to housing in the West Midlands and to knock heads together where there are obstacles it would be a surprise to see any such mentions again. There can be few areas of the country where administrate arrangements are so byzantine (the image below is care of Barton Willmore). Instead we can expect to hear about how the WMCA has “shifted the whole basis of housebuilding in the region”. This is true. The Position Paper states that the main reason behind the reduced shortfall is an increase in supply in Birmingham of 13,942 dwellings, which represents a remarkable 27% increase from data published only three years ago.
There is a serious point here that can be lost in talk of ‘shortfalls’, ‘targets’ and ‘algorithms’. Birmingham’s 2013 Strategic Housing Market Assessment anticipated that of the 80,000 homes required in the city by 2031 46% would need to have 1 and 2 bedrooms and 54% would need to have 3 and 4 bedrooms. Since then average annual delivery in the city has been 68% 1 and 2 bedrooms and 32% 3 and 4 bedrooms. Indeed, of 3,865 homes completed in the city in 2018/19, 75% had 1 and 2 bedrooms and 15% had 3 and 4 bedrooms (this data is from BCC’s most recent Annual Monitoring Report). On paper targets are being met and shortfalls are being dealt with, but units are not homes (for more details on the impact of the standard methodology on planning for housing please see this report for BDW by the University of Liverpool and for more details on the financial consequences to younger households in northern and midlands Core City regions of being stuck in the private rented sector due to inadequate supply of homes for owner occupation please see this report for BDW by Lichfields).
Back to the election and it can also be expected that Mr Street will make great play of Government backing for the WMCA’s ‘business plan’ and the ‘£350m investment in our Housing Deal which was recently topped up with another £84m’.
It was in the July of 2018, after the announcement of the Housing Package that March, when it was possible to gain an understanding of just how the afore-mentioned 215,000 new home target in it had been arrived at (it assumed that the 2031 target date was alighted upon to align with the BDP plan period). Papers presented to a WMCA Housing & Delivery Board indicated that it was no more than the housing requirement for constituent and non-constituent authorities in existing and (untested) emerging plans, plus provision for shortfalls accruing against it. As I have written before, one imagines that in conversations with Whitehall mandarins it was possible to spin that figure (and indeed it is probably still being spun) as both being a bold and transformative step change in delivery and a commitment to harmonious cross-boundary working, but it is worth keeping in mind when that figure inevitably does come up that any upswing in unit completions was only from what was happening to what should have been happening anyway, let alone what could have been happening or what needs to happen to meet future housing needs.
More positively, in recognition perhaps of the Black Country’s Urban Capacity Review and the shortfall there of 27,000 homes up to 2038 Mr Street’s rhetoric on Green Belt is softly, but perceptibly shifting. There is reference now not to no building on the Green Belt at all to not having to build on any Green Belt here ‘until 2031’ (a date alighted upon presumably to align with the Housing Package target). That of itself though does not make the job of a policy planner much easier right now of course (though pity the poor development management officers who had to deal with Mr Street’s objections to planning applications on allocated former Green Belt sites in Coventry).
Finally, if this six year soap opera was not depressing enough there is the fallout from the ‘Planning for the Future’ White Paper to look forward to next year. Given that the Duty to Cooperate has been the only formal mechanism for triggering any kind of cross-boundary communication across the conurbation, and given that it has proven to be an abject failure both in West Midlands and elsewhere, what will be the repercussions of it’s removal? I will leave that not insignificant question hanging there as the hook to hang, if I am still working in the West Midlands, next year’s blog on.
What is the state of devolution and the Birmingham shortfall at the end of 2020? A Housing Package that looks backwards; a Position Statement that was out of date as soon as the ink dried on it let alone whenever it gets subjected to scrutiny by an inspector; local leaders only ever looking as far as the next election; and the future left to sort itself as out.
Plus ça change.
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