A.  GENERAL OBSERVATIONS ON THE STATEMENT

  1.  The Deputy Prime Minister's July statement only partially responds to its stated objective that "We need more homes where people want to live, near where they work, in the North and the South, at a price that people can afford and in a way that protects the countryside". Its approach is too simplified, fails to take account of the complex dynamics of housing markets and people's aspirations. As a consequence it focuses on a too limited range of issues.

  2.  In the West Midlands we have been examining these issues through the Regional Housing Partnership and in the preparation of our Draft Regional Planning Guidance. While a critical area of concern in the West Midlands is that of the failure of the housing market in certain older urban areas, we do recognise that housing will also be a key driver of Urban Renaissance throughout our urban areas. We have been pro-active in the development of the Housing Market Renewal initiative with central government and are pleased that this has been recognised by the Government in the proposals for two of the Pathfinder projects to tackle acute problems of low housing demand and abandonment being set up within the West Midlands. However, we believe that policies need also to be developed for other residential areas if we are to truly create the conditions within our urban areas in which people with choice will actively choose to live. This is one of the fundamental components of Urban Renaissance that we have identified. Across the Major Urban Areas (MUAs) in the West Midlands Region the role housing plays in Urban Renaissance cannot be underestimated.

  3.  We feel therefore that the Deputy Prime Minister's statement underplays the role of housing in regeneration. Through the RPG review process in this Region we have sought to look at the wider picture in the provision of housing, and other forms of development. There is great emphasis placed in the draft RPG on quality, and not just the sheer number of homes to be provided. New homes should be brought forward in quality environments, which in many cases will involve the extensive regeneration of existing urban areas.

  4.  Much of the current discussion on housing is focused on the scale and location of housing provision in the South East Region. We are concerned that this will potentially send the wrong message to the private sector in terms of how they should be responding to the emerging strategies in other regions. Indeed it may well not be serving the interests of urban renaissance in the South East either. This is particularly felt to be the case for the West Midlands region, with its central geographical location transacted by key transport routes and its proximity to the South East region.

B.  THE WEST MIDLANDS STRATEGY—WHAT WE AIM TO DO

  5.  The proposed housing strategy of the Draft RPG for the West Midlands (November 2001) is firmly woven within the overall spatial strategy, with its reversal of previous policies which have encouraged decentralisation in favour of a strong focus on Urban Renaissance. At its core is the need to create a variety and choice of good quality housing throughout the MUAs. In doing so, bringing to a halt and beginning to reverse the trend of Metropolitan MUA decentralisation.

  6.  This is complemented with an approach to housing beyond the MUAs which focuses on providing new housing in sustainable locations at a level which meets local housing needs (in the Draft RPG local housing need is defined as the locally generated households adjusted to reflect the effects of inter-regional and international migration). Sub regional foci for development beyond the MUAs are identified to reinforce this strategy. These include settlements where it is considered that new housing can be focused without adversely effecting efforts to concentrate new housing provision in the MUAs.

  7.  Market and Housing Renewal Areas (two of which in Birmingham/Sandwell and Stoke -on-Trent are now identified as Pathfinder Projects) form part of this strategy and identify areas where radical large scale change is needed to create new choices. However, our approach is comprehensive, aiming to raise quality throughout urban areas, so that they are attractive to a broad range of people's expectations and lifestyles. Our wider aim is to "create sustainable urban communities and this will require different approaches in different areas reflecting the range of social and economic circumstances in differing neighbourhoods ie:

—  The most deprived areas, including outer estates;

—  Neighbourhoods vulnerable to decline;

—  Traditional suburban areas with opportunities to raise densities, support local services and improve quality of life;

—  All other neighbourhoods where it will be important to improve services and enhance the environment."

  (West Midlands Regional Planning Guidance Review—Draft RPG, November 2001).

  We would expect a major Government policy statement to reflect this breadth of issues.

  8.  An Implementation Framework to deliver the Draft RPG is being prepared, and work is ongoing to bring the emerging Regional Housing Strategy, steering housing investment, into closer alignment with the Draft RPG. At a regional level we are proposing the identification of "demonstration projects", particularly to test the concept of raising densities within existing residential areas at the same time as enhancing quality of environment.

C.  RESPONSES TO THE IDENTIFIED SPECIFIC MATTERS OF INTEREST

The overall scale of house building required

  9.  We are adopting a sub-regional approach in the West Midlands to housing provision. Six sub-regions have been identified with housing provision to be made for each sub-region to meet locally generated needs wherever possible. An over-concentration on housing numbers will not provide the housing we need. It is not just overall scale which is important but also the location, type, tenure and quality. We believe that the most sustainable approach is to locate new homes close to where need arises of a type, quality and tenure required to meet aspirations set out in Community Plans and to support regional planning and economic strategies.

Are the proposals likely to significantly reduce house prices?

  10.  The increase in house building proposed in parts of the South East is unlikely to significantly reduce house prices. Other factors, such as the continued economic success and overheating of the South East, are likely to continue to keep prices high.

  11.  This is reinforced by research undertaken by Halcrow Fox for the West Midlands Regional Forum of Local Authorities (predecessor to the West Midlands Local Government Association) in March 1996. Part of the research focused on whether land supply could be managed to influence access to housing by lower income households, and specifically examined whether the allocation of excess housing land reduced land and housing prices. They examined a range of research at the national and regional level and in their findings considered that in high demand, high constraint areas, a radical increase in land supply would reduce the price of new houses, but have no effect on existing houses.

  12.  Economic development needs to be more evenly distributed throughout the regions, steered by the RESs and RPGs. This needs to be integrated with Urban Renaissance if we are to achieve "big" objectives of sustainability, quality of life, social inclusion and community cohesion.

THE GEOGRAPHICAL DISTRIBUTION OF NEW HOUSING, INCLUDING PLANS TO CONCENTRATE DEVELOPMENT IN THE SOUTH EAST IN FOUR GROWTH AREAS, MILTON KEYNES, THE CAMBRIDGE/STANSTED CORRIDOR, ASHFORD AND THE THAMES GATEWAY

Whether the proposals will promote high quality sustainable communities whilst avoiding poorly designed urban sprawl

  13.  The focus could be broadened from the existing proposals for four growth areas in RPG9, to place more weight on the regeneration of existing urban areas where poorer environments currently exist within the South East region. These locations should be close to where key workers work, provide the opportunity to use public transport and access a range of services, such as good schools, healthcare, leisure centres etc, and provide the opportunity for "lifecycle" house moves within an area so that people have the choice to meet their housing needs without having to move outside their community.

  14.  This approach would help to deliver an overall boost in regeneration, significantly increase the quality of declining urban areas and lessen the amount of undeveloped land taken for new housing. In short it would be more sustainable and contribute more to raising quality of life.

  15.  The functional relationships between the four growth areas and the local housing markets within which they operate need to be understood to ensure that the regeneration of urban areas are not jeopardised, particularly if these four growth areas are to be accelerated as proposed by the Deputy Prime Minister. In the West Midlands, where a more simplified pattern of housing markets operate, it is felt that the current RPG strategy (RPG11, 1998) has contributed to a "hollowing out" of parts of the Birmingham and Black Country conurbation and the North Staffordshire conurbation, due to the high amount of new housing located close by in the shires. Locations for regeneration need to be complemented, not jeopardised by the location of any growth areas.

  16.  The implications for inter-regional migration from the accelerated growth areas also need to be fully worked through. The accelerated growth could lessen the pressure for new housing and employment in the southern parts of the West Midlands. On the other hand inter-regional migration from the South East to the West Midlands could significantly escalate from the current level if new housing development is accelerated, particularly from the Milton Keynes growth area. The good transport connections and close proximity to the most economically buoyant areas of the West Midlands could mean that more people look for and secure jobs in the West Midlands rather than in the South East. This could potentially undermine the overall strategy of the draft RPG in the West Midlands and dilute what is trying to be achieved in the South East. Synergy between the location and rate of development in the growth areas in the South East and other regions is needed, and adds weight to the argument for a national strategy.

Proposals for new Millennium Villages

  17.  Millennium villages are just one tool of promoting Urban Renaissance in a more environmentally sustainable manner. In the West Midlands we have not focused on this approach, favouring a wider approach through strengthening the overall spatial strategy by focusing on community regeneration in the MUAs. Nevertheless, we will examine the use of the Millennium Villages approach in our option appraisal of areas in which we think significant change will be desirable, for instance within our Housing Market Renewal Areas.

The balance of new development between housing for sale and social housing

  18.  In some areas the balance could swing to 100% affordable housing, including low-cost market housing (sold at discounted market rate) and social housing. In other areas we have a surfeit of social housing for which there is limited market demand. Local analysis within sub-regional market assessments is essential to determine appropriate balance—we must not adopt blanket policies on this. Both low-cost and social housing have been included as contributing towards affordable housing in the definition adopted by the WMLGA in August 1999. Although the provision of affordable housing through the low-cost route has been low to date, there may be scope to increase its role in the future. Refer to recent research findings on the success of low cost.

The extent to which decisions relating to housing, including numbers, tenure and density, should be taken by central and local government

  19.  A strategic steer for housing numbers is needed to ensure that regional strategies stand a fighting chance of being achieved. District/Mets. Cross boundaries approach to tenure is needed based on experience in recent years with the low provision of affordable housing and the need for consistency in order to effectively deliver the number and type of affordable housing required. Strategic steer for tenure would need to be tested at the local level and adjustments made if required. With regards to density the emphasis needs to be on quality and range, with a view to increasing housing density whenever possible. Arbitrary ratios need to be avoided, though the Deputy Prime Minister's proposal to intervene in planning applications that are of a density less than 30 dwellings per hectare is supported. Suggest at the local level authorities seek percentage increases on existing densities, reflecting the locational variations and individual characteristics of various typologies of housing, as suggested in paragraph 7. In summary, a strategic steer from Government would be beneficial but we do not want prescriptive "top down" policies. Sub-regional approaches, which bring together local market analysis and wider policy framework should be encouraged.

D.  THE REGIONAL HOUSING PARTNERSHIP IN THE WEST MIDLANDS

  20.  The Regional Housing Partnership in the West Midlands was formally set up from a WMLGA Chief Housing Officers Group. It has a wide membership of stakeholders, comprising officers from local authorities, housing related organisations and businesses across the Region. It meets at regular intervals to discuss and provide advice mainly on policy and strategy development, housing innovation, community regeneration and investment priorities. Subregional groups have also been established to meet networking gaps identified by the Forum. It now formally reports to the West Midlands Regional Chamber.