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We have a general concern at the method of using three Options as a basis for consultation, as it invites incoherent responses that may not match housing and employment growth. We are also concerned that the assumptions made on overall level of housing need may be unsound. Although we agree that affordability indicates a current underprovision, demographic change indicates that that the number of persons per household may now be levelling out and that future demand may be more closely allied to population growth. Thirdly, we do not consider that urban capacity has been adequately taken into account.

In so much as the lack of robust evidence will allow we support an overall level of housing approximate to that proposed in Option 2. Option 1 falls well short of existing evidence of local need and Option 3 could well represent a wasteful level of overprovision, as well as raising environmental and infrastructure issues due to possible large scale development on greenfield sites.

In Option 1 the level of overall housing development is probably too small and many of the non-MUA area would be unable to address local need. Although the MUAs can accommodate more than the totals proposed in this Option and the balance could easily swing towards them, we would not advocate such a change for the reason above. This balance is stretched to a questionable degree in Option 2 and is wholly unacceptable in Option 3. Option 3, with the proposed balance, would represent a complete reversal of policy and would not be consistent with a mere partial review. It has been suggested that inadequate land is available in the MUAs to adhere to the current policy of concentrating development in the MUAs under Option 3. We have seen no evidence as yet to either support or contradict this view. It is our view that the policy of concentrating development within the MUAs should not be reversed. Option 3 concentrates housing in the commuter towns around the conurbation. This is an unsustainable solution, particularly considering the current congestion problems and inadequate public transport infrastructure to deal with the extra commuters.

For Option 2, the balance could clearly be concentrated further on the MUAs. If the MUAs can accommodate the numbers proposed for them in Option 3, then they could feasibly accommodate the same totals under Option 2, and thus a much larger proportion. It has been suggested that a target of 58% for the MUAs should be attainable. Allocations to some MUAs, e.g. Stoke on Trent, fall well below urban capacity. This may reflect a view that lack of demand is an issue, but this fails to encompass the argument for regeneration. The Regional Economic Strategy is likely to emphasise regeneration of the MUAs with a view to making them more attractive places to live, as well as revitalising their economies. The Regional Spatial Strategy should therefore reflect the need to regenerate MUAs, and complement the Regional Economic Strategy in this respect.

We do not believe that Option 3, or Option 2 at the proposed distribution, represent sustainable patterns of development for the region in the period to 2025. To limit the need to commute by car it is necessary to concentrate growth within the MUAs, but to ensure that the centres outside of the MUAs have sufficient housing allocations to meet local need.

We do not believe that the construction industry would have a problem coping with any of the Options in terms of building the requisite numbers, but there is a shortage of skills in the production of energy efficient buildings. We are concerned that developers will convince Local Authorities to lower standards if this skill shortage is not addressed. There is a danger, considering current proposals to tighten regulations on both energy efficiency and renewable energy provision, that developers may seek to bring forward large numbers of sites in high demand areas at an early stage, so that they can build as many as possible to current standards. Phasing may be necessary to overcome these problems.

Considerable infrastructure spending is already required to address the congestion problems of the Region. We have addressed this issue in some detail in our response to the Regional Economic Strategy Review. Considering the current levels of congestion and the subsequent commuter journey times from the surrounding commuter towns into the conurbation, we strongly advise that housing development in these commuter towns is limited, at least until the transport infrastructure problems have been addressed. Current journey times for a 20-mile drive into the conurbation are now around 90 minutes at peak times. Using the train is not an option for any more commuters as 1) the trains are already overcrowded and 2) the station car parks are all full before the commuter rush is over. Some large commuter settlements either have no direct service to the conurbation (e.g. Atherstone) or have no station at all (e.g. Kenilworth, Burntwood, Wombourne). Even with the levels of housing development proposed in Option 1 investment in transport infrastructure is imperative, particularly a good choice of Park and Ride stations with regular services into the conurbation.

Many of the commuter towns have a shortage of good quality jobs and experience reverse commuting. Highly qualified residents commute into the conurbation, whereas low skilled workers commute out to fill service jobs and the predominant form of employment in the distribution centres. An emphasis on providing office employment is required in the commuter towns to help match jobs with people.

Any new build that does take place on greenfield sites should be at the most sustainable locations for transport purposes. They should either be near to current railway stations or at points where new stations can be built to serve them. If the latter, it goes without saying that the provision of such a new station should be a condition for development.

New build should be designed to cater for local need rather than outmigration. This means including suitable proportions of social and affordable housing as well as a suitable proportion of executive homes to fit that need. These issues are best decided at Local Planning Authority level, but Regional planning policy should allow maximum flexibility.

It is necessary to insist on the highest level of energy efficiency for the new homes and also to include renewables in the energy supply if the targets for carbon neutral housing are to be reached by 2015. It is our view that the government's target of achieving this standard by 2015 is unambitious and risks large numbers of houses being built that could have been, but are not carbon neutral. Housing stock lasts for centuries rather than decades and it is vital to address the carbon footprint of new build at the earliest opportunity if we are to feasibly meet the targets for reduction in carbon dioxide emissions set out in the EU Energy Strategy of 2007. The technology is already available and other European countries are already using such standards. We believe that this target should be brought forward to 2011 and that the Region should seek to achieve this deadline.

We have real concerns that Option 3 in particular concentrates development in a ring around the conurbation, in effect creating a doughnut effect. Option 2 also tends in this direction, but less emphatically. Peripheral parts of the Region and its core would be subject to smaller percentage increases in housing stock under these options than the commuter ring of the “doughnut”. This is not a sustainable pattern of development. We remain to be convinced that a larger proportion cannot be accommodated by the MUAs and also believe that some of the peripheral areas might agree to more development.

Only a single proposal for distribution of housing is given for each Option of overall provision. In many cases the district allocations look arbitrary, failing to reflect local demand, identified urban and brownfield capacity or local geographical, environmental or infrastructural constraints. Option 3 for instance proposes housing levels in excess of demand in Staffordshire, but still failing to meet demand in some other areas.

See above. There may be more capacity within the MUAs than estimated. Robust urban capacity studies must provide evidence for the inability of the MUAs to accommodate more development under Options 2 and 3. It is inconsistent to indicate that the MUAs can accommodate 46,000 less dwellings under Option 2 than is possible under Option 3. An exception is Solihull, which will struggle to accommodate the numbers allocated under Option 3 without resorting to Green Belt development.

The principle of identifying sub-regional foci is sound, but the practice is fraught. A number of important sub regional centres with a wide range of facilities should reduce the need to travel into MUAs and help achieve a better quality of employment in these centres, again reducing the level of commuting. However, there is no indication of how the sub-regional foci will be helped to cope with extra housing, how their additional infrastructural needs will be met and how the level of facilities required will be delivered. As a result, there is considerable opposition in all of these proposed sub-regional foci, with the possible exception of Telford, to their designation.

There is concern in the designated sub-regional foci that the housing allocations are excessive, particularly under Options 2 and 3. The possible exception is Telford, where there seems to be support for the growth of the town to a population of around 200,000. If Telford is to be developed to this extent, it must receive appropriate infrastructure investment. Such development should be conditional on the extension of electrification of the railway and direct services to London. London to Wolverhampton services should then be extended to Shrewsbury, the logical terminus due to other routes converging there.

Hereford, Worcester, Shrewsbury and Rugby have indicated significant opposition to their designation and the level of housing growth at these centres is viewed as alarming, although Shrewsbury and Atcham may deal with this problem through an accommodation with South Shropshire.

The high level of housing growth projected for Burton on Trent, a potential sub-regional focus, is opposed by Liberal Democrats in East Staffordshire. They point out that they do not have sufficient brownfield sites and that the South Derbyshire option is unlikely to materialise. Drakelow in South Derbyshire is the only large brownfield site nearby and it has not been brought forward as a strategic site by EMDA. Burton is a long commute from Birmingham, although less so from Derby. The station does not have much scope to increase car parking and facilities for extra commuters will not be easy to provide.

Those authorities that have neighbours unable to accommodate totals allocated under Option 3 would have great difficulty in delivering sustainable solutions for the numbers proposed under this option. Authorities neighbouring Worcester such as Wychavon and Malvern Hills, for instance, would have to build beyond the Worcester ring road, rendering it unfit for its present purpose, as well as threatening nearby villages with urban sprawl. The rural nature of these districts would be difficult to maintain.

Lichfield also has a similar problem with Option 3. The excessive allocation for Lichfield District itself would be difficult to accommodate alone, without the extra allocations likely from Tamworth, Cannock Chase and possibly East Staffordshire. It is notable that under Option 3 Burton on Trent would be identified as a sub-regional focus, yet Licfield would be subject to greater housing growth. Lichfield District has a particular difficulty in that the entire area to the south of the West Coast Main Line is Green Belt. This would force leap-frog development further out from the conurbation, to the north of Lichfield, Tamworth and Rugeley and beyond the transport links. Existing policies are in place to protect the approaches to the historic city of Lichfield, with particular reference to views of the cathedral. Allocating the lion's share to the periphery of Lichfield City would require it to double in size and coalesce with settlements to the north. The A38 is already congested and could not cope with the extra traffic.

Development to the north of Tamworth is also problematic for two reasons. Firstly, only one road feeds into Tamworth town centre from the north. Access to the town centre, railway station and the M42 for those continuing to the conurbation, would all require to use this one route via the town centre. Furthermore, the M42 itself is hopelessly congested for several hours each day. Secondly, the tongue of land not designated as Green Belt to the north of Tamworth is narrow, and accommodating a significant number of houses would require a large projection northwards deep into the only large area of open countryside between Birmingham and Derby. The other option for Lichfield District, to expand in Burntwood, is a non-starter, as Burntwood is hemmed in by the Walsall boundary, Green Belt and Cannock Chase AONB. Lichfield could just about cope with Option 2 through a new/expanded settlement at Fradley. Unfortunately the favoured airfield site is too far from the Lichfield to Burton railway to be served by it adequately and would add to traffic on the congested A38. Another option would be to develop nearer to the railway, but this is a purely green field site.

Timetable proposals by Network Rail at settlements along the West Coast Mainline are not conducive to extra development as it is planned to cut Pendolino services to London to assist more through services from the North West. There is also a possibility that local services from Tamworth may be diverted into Moor Street, taking away the alternative option of changing in Birmingham for London services. These are prime examples of the lack of joined up thinking between the planning of development and transport links.

Burton on Trent should not be extended on green field land. The only direction to do this would be to the west, into the attractive countryside of Needwood Forest, as north and south is the Trent floodplain and to the east the town is already built to the regional boundary. Other comments have been made in the answer to the previous question.

Sub-regional foci should only be so designated if supported by their Local Authorities and any neighbouring LAs that would be affected. Where there is broad local support, then this approach should be followed. However, housing alone will not create a sub-regional focus. The foci will have to provide certain regional level services and will need extra infrastructure spending. Their added importance would need to be reflected in a higher level of rail services, particularly as Inter City stops. Employment land and office development would also need to be stepped up, not only to cater for the extra inhabitants, but if they are truly to be foci, to provide jobs for those who currently commute to the conurbation. Currently, apart from Telford, there is too little local support this policy in the proposed sub-regional foci. If this support cannot be engendered, then it would be better to abandon this policy.

This is best left to Local Planning Authorities. It may be impractical to set regional targets for social and affordable housing and it might be best to allow Local Planning Authorities to set their own. If regional targets are adopted for affordable and social housing they should be framed to ensure that Districts develop targets that will deliver the regional targets. Districts have widely differing needs. Each LDF would need to show that it addressed local need to comply with the RSS. One LA might only need to provide 5% affordables, whereas another might need to provide 50%. It would have to be explicitly explained to LAs that any regional target would not be indicative of their own LDF targets. The Regional Assembly would need to develop some expectation of what is required in each District for the regional target to be finally met, in advance of the LDFs coming forward. A better approach might simply to allow regional guidance to give planning authorities a maximum level of flexibility in setting targets and thresholds.

If either of the approaches detailed above (H10) are followed, there will be no need for a minimum affordable housing target. The danger of adopting a minimum is that it would have to approximate to the requirement of the LA with the smallest need for affordable housing. Other LAs would then interpret the figure as indicative and it would be difficult to attain the regional requirement.

The role of the region should be to support Local Planning Authorities in their attempts to deliver the levels of social housing that they consider appropriate. The RSS should include policies that allow Local Planning Authorities to use lower thresholds for negotiating 106 agreements. There is no need for the RSS itself to identify these areas as long as Local Authorities are supported in their own assessments.

This question is best answered from each local authority area. It is clear that houses built as free-market affordables in desirable areas are well beyond the budget of first time buyers and are not addressing the problem. Only social housing will address the problem of young people being able to find a home in such areas. Certainly Lichfield and South Shropshire have this problem, but they are not alone. Colleagues in Sandwell have informed me that they have the opposite problem, in that it is difficult to retain the more successful members of their communities due to a lack of more upmarket housing. Colleagues in Birmingham indicate that their particular need is for social housing due to attrition of the social housing stock through right to buy.

No. There is already a problem in high demand areas of developments being brought forward even ahead of LDFs formally allocating land. Bringing land forward in foci and other high demand areas will result in green field sites being developed ahead of brown field sites in the conurbation. This will increase reluctance by developers to develop brown field sites at a later date, particularly if the overall increase in housing supply is successful in damping house prices. Additionally, developing the foci ahead of the MUAs will be likely to result in housing numbers getting ahead of infrastructure development.

A second consequence of early release has been detailed in our answer to Q H5. In response to the need to reduce carbon dioxide emissions to address the problem of climate change, more stringent standards are being developed for both energy efficiency of new houses and the use of renewable energy in new developments. The UK is already well behind the EU average in standards achieved and the government has announced its intentions of achieving 100% carbon neutral new build by 2015. We believe that this standard should be achieved by 2011 at latest. Phasing will be necessary to prevent developers building as many houses as possible in advance of higher standards being introduced. The EU Commission intends to revisit the Energy Efficiency of Buildings Directive this year in order to tighten up on minimum standards. It is unlikely that UK government will legislate quickly enough to head off a rush to build at lower standards. The RSS should include policies to insist on standards that meet current EU standards, such that those standards applicable in the West Midlands will be automatically updated on the review of the Directive. Secondly, the RSS should include appropriate phasing to prevent any rush to build at the lower standards that currently apply. Thirdly, phasing should follow a sequential approach, with brownfield sites developed first, followed by other sites in more sustainable locations. Sites requiring significant infrastructure investment should be held back until that infrastructure is provided.

Minimum allocations are probably appropriate in all cases. Districts would then have the option of building more for local need if they so desired. However, phasing might be necessary to prevent a de facto reversal of the policy of concentrating development in MUAs.

Areas of employment land are becoming less relevant as we approach a post-industrial employment pattern. However, large sites may still be required on occasion and some regional involvement is required for the largest site requirements. Strict allocation of employment land to each District is unnecessary. Districts should have more freedom to make their own decisions. Employment density is now so variable that land areas allocated are virtually meaningless in terms of job numbers.

If the RA insists on including District allocations for employment land, they should take more account of housing allocations. Housing Options 2 and 3 as proposed are not followed by allocations of employment land, which is still more concentrated on the MUAs. Concentrating housing in the commuter belt and employment land in the MUAs will increase further the need for commuting. This is not a sustainable strategy.

A regional allocation and a reservoir are required for large sites only. Indicative targets for LAs may be appropriate on a number of jobs basis. We question the need to restrict the reservoir of employment land in any authority. This is again pertinent where large employment sites such as former collieries or airfields are developed over a protracted period.

It would not be appropriate to include such guidance in the strategy. It would however be useful for the strategy to require LAs to provide information through the RPB on their portfolios of employment land; the information to be made available to all Local Planning Authorities to inform their own policies.

The Midlands has become the logistics hub of the country for obvious location reasons. However, this growth has also contributed to the increased levels of congestion in the region. Concentrating growth on regional logistic sites with rail access is the least worst option. Care must be taken not to overestimate further growth in logistics using current movement patterns. Road user charging and increases in oil prices are likely to change the pattern of goods distribution and some companies are already looking at possible future changes.

This should be left to Local Planning Authorities in their LDFs. Non-strategic centres may require more shopping space to reduce the need for shoppers to travel to larger centres. It is unlikely that the retail industry would be interested in developing to a degree not supportable by the market in smaller centres. Artificially restricting development of shops in smaller towns creates a need to travel to more distant shopping centres. This is a strategy that is not consistent with sustainable development and there is no good reason why the larger centres should need protection.

We support the concept of allocating a high level of office provision to areas with two way commuting problems caused by a mismatch in the level of skills in the local workforce and the quality of local jobs. However, this is again an area where Local Planning Authorities may know best. Some areas allocated large office developments may be constrained by availability of appropriate sites and therefore may be unable to deliver their allocations.

Yes. Town centre sites should be the first place to develop office space, alongside other sustainable sites with good public transport links. Large out of centre sites should be a last resort, although dispersed office provision in rural areas may be a sustainable option, reducing the need for a rural workforce to commute to an urban centre.

Maximum percentages for out of centre office sites may be attractive, but may be impossible for some authorities to meet. Also, such a policy would fail to accept that some rural office provision is sustainable. Large out of centre sites should be restricted by using the sequential approach, but small rural office sites should not be restricted in the same way.