Supplementary Memorandum by the West Midlands
Regional Assembly (WMRA) Secretariat (AH 55(a))
APPENDIX 1
RESPONSE OF THE WEST MIDLANDS REGIONAL PLANNING
BODY TO THE ODPM CONSULTATION, "HOUSING AND PLANNING IN THE
REGIONS"
The Regional Planning Partnership of the West
Midlands Regional Assembly met to receive a full and detailed
paper at a specially convened meeting on Friday 19 November 2004.
The consultation response comprises this letter and the appended
summary report to the Regional Planning Partnership of 19 November
which is attached in full. Also appended as part of the formal
response is the relevant extract of a longer report to the Regional
Planning Partnership (RPP) on the same date which contains the
formal recommendations on this matter which were agreed by the
RPP. This letter contains some key points the Partnership felt
should be stressed in this response.
The intention to merge the Regional Housing
Board and the Regional Planning Body was generally welcomed in
principle as it helped to address the criticism that the Regional
Housing Boards are currently undemocratic. In addition the closer
working of both Housing and Planning regional processes builds
upon the West Midlands approach to partnership working and is
welcomed.
You will see below the preferred form in which
this merger should take place which the West Midlands Regional
Planning Partnership agreed. This ensures parity of influence
and esteem between the disciplines in the Regional Assembly structures.
Cross membership between Planning and Housing bodies and occasional
joint meetings should be sufficient for this process to work well
under the overall control and ultimate resolution of the Regional
Assembly itself. Membership of a new Regional Housing Partnership
would reflect the proportionality currently prevailing in the
Regional Assembly structures, namely 4:1:1 between, elected LA
Councillors, the business community and the other regional stakeholder
representatives.
The one issue which members felt most strongly
about was the need for this merger to be properly resourced. Failure
to do this would prejudice the success of this venture from the
outset. The production of the Regional Housing Strategy, the Regional
Housing Allocation Strategy, the servicing of the current Regional
Housing Board and the allocation function advising the Minister
on the split of funds to local housing authorities and to Registered
Social Landlords, all require proper resources to be executed
effectively. Up until now the West Midlands Government Office
has found the resources within its own organisational arrangements
to absorb these costs. The GOWM is a much larger organisation
than the Regional Assembly. No such flexibility exists in this
much smaller and tightly constrained organisation. Without the
delivery of appropriate financial resources ODPM should not embark
on this course. In the worst case, in the absence of these additional
funds the Regional Assembly may be forced to decline the opportunities
offered by the merger. The WMRA secretariat would welcome further
discussion with GOWM/ODPM about what it is that you are actually
proposing in detail in order to demonstrate the clear logic and
justice of this position.
Turning now to the second part of the Barker
Recommendation 6, the West Midlands Regional Planning Partnership
was much less convinced of the ODPM case for establishing a national
advice unit.
The ODPM consultation has perhaps been less than
helpful to its own case in that important aspects of the proposal
are less than plain. In short the West Midlands Regional Planning
Partnership was not persuaded of the merits of the national advice
unit, and the degree of apparent sophistication intended in its
governance.
The West Midlands Regional Planning Partnership
feels the emphasis on "independence" is illusory and
misleading. No experts are free of professional or political bias,
especially when working in the public sector policy domain. As
such their functions in devising advice and in monitoring and
reviewing compliance simply cannot be undertaken without making
"political" judgments. The same views apply to the reservations
about the "independent" oversight committee.
If the Minister is minded still to proceed with
the formation of this national advice unit, the West Midlands
Regional Planning Body would be willing to accept a non statutory
advisory body issuing non mandatory advice on methodologies and
general advice on affordability issues.
In the event that a national advice unit is
created it would be preferable to have a Regional representation
from each English Region engaged with it in some formal relationship.
The suggestion that has been mooted for a Regional Sounding board
to work with the national advice unit would be supported and welcome,
though some other arrangement engaging all of the Regions could
be equally useful and acceptable.
The integrity of the Regional Planning Body
as the regional planning policy advisory body to Ministers is
valued very highly by the Regional Assembly. The creation of an
"independent" unit which may prescribe either directly
or indirectly the way land release for housing in the Region should
be conducted would be seen as undermining the discretion of the
Regional Planning Body. It is whether the consultation document
does or does not intend this that leaves the Regional Planning
Body unable to respond more precisely until ODPM makes its proposals
plainer.
Government attention towards issues of affordability
is welcomed, and shared by the West Midlands Regional Planning
Partnership. However the intention to persist with shaping the
Regional Planning process through the Barker Agenda, as clearly
stated at para 1.10 of the consultation paper, remains the most
serious concern to this Region and its partners. The concern about
the potentially unworkable nature of the Barker Agenda in the
West Midlands has been explained before in our response to the
Final Report. To repeat, the logic of this concern is that this
Barker model is very likely to be unworkable within the rationale
of the Regional Spatial Strategy for the West Midlands. West Midlands
Regional partners worked hard to achieve this challenging but
vital urban and rural renaissance strategy, now approved by the
First Minister in June this year. The West Midlands Regional Planning
Body would be dismayed to see it reversed by the imposition of
an inappropriate solution, founded upon a short run economic model
driving land release changes which would only perpetuate unsustainable
regional trends.
The overwhelming logic of our regional sustainability
agenda sets a long trajectory course to genuinely and sustainably
address issues of affordability. It should achieve the same theoretical
ends but via sustainable routes. The West Midlands Regional Planning
Body would not wish to see its Regional Spatial Strategy driven
off track by advice from a national unit pursuing the logic of
oversimplified, idealised, theoretical models of supply and demand.
The results of such an approach could be seriously damaging to
parts of the Region where high demand, high prices and high affordability
issues exist at present but precisely do not need additional quantities
of more market housing as a false solution.
Steve Forrest
Strategic Housing Advisor
29 November 2004
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