Memorandum by Merseytravel (PGS 25)
It is with pleasure that we submit evidence
as part of the Committee on the Office of the Deputy Prime Minister's
inquiry into the Government's proposals to introduce a planning
gain supplement.
We have also made a submission to HM Treasury's
own consultation as we believe that Kate Barker's recommendations
need to be considered in more detail. We firmly believe that the
Government are right to look at the issue of contributions from
developers given that one thing is very clear: the existing system
is not satisfactory.
Using PGS to provide additional infrastructure
investment would be extremely worthwhile. We were, however, very
worried that whilst the consultation document on this issue mentioned
transport as being an example of the type of major infrastructure
projects being considered, there was no reference to Passenger
Transport Executives (PTEs) or Passenger Transport Authorities
(PTAs).
Transport is an essential element of the vast
majority of developments but, unfortunately, there are many examples
of large scale developments that take little note of education,
health or transport needs.
ABOUT MERSEYTRAVEL
Merseytravel is a public body comprising the
Merseyside Passenger Transport Authority (MPTA) and the Merseyside
Passenger Transport Executive (MPTE), acting together with the
overall aim of providing a single integrated public transport
network for Merseyside which is accessible to all.
In planning and procuring major elements of
the public transport system, Merseytravel funds socially necessary
bus services, oversees local rail and bus services, owns and operates
the Mersey Ferries and the Mersey Tunnels, provides a range of
prepaid and concessionary tickets, produces and distributes timetables,
and prepares and implements the local transport plan for Merseyside
with our district council partners.
We have an impressive record of delivery across
all aspects of the transport system in Merseyside and have been
recognised for our high level of customer care, professionalism
and innovation, winning the Joe Clarke Award for PTA of the Year
for the second year running. We also recently claimed the Northwest
regional "Award for Skills and Workforce Development",
one of a handful of awards announced as part of the British Chamber
of Commerce and Microsoft sponsored "Chamber Awards 2005".
Merseytravel has delivered a number of major
infrastructure projects and has several more in development. Many
of our developments are designed to create an infrastructure that
supports private sector investment in Merseyside but without a
financial contribution from them. In particular, we have:
(i) Introduced state-of-the-art bus stations
and on-street waiting facilities.
(ii) Undertaken improvements to two of the
safest road tunnels in Europe, now coping with 26.9 million vehicles
per annum.
(iii) Recently opened a new multi-million
pound Interchange, the Paradise Street Interchange, which will
give up to 10 million people every year direct access to jobs
and leisure and shopping facilities in and around the giant development
currently under construction in the heart of the city.
We will shortly be opening Liverpool South Parkway,
a key gateway into Merseyside for visitors by rail and air, and
a new Pier Head building for Mersey Ferries is planned in keeping
with the area's World Heritage Site status.
It is clear that the nature of our business
means that we are actively engaged in the planning process. The
new development work we undertake is often in response to changes
in travel patterns which are commonly caused by changes to the
physical environment in an area.
QUESTIONS
Q1 The factors which should be taken into
account in determining the rate of the supplement and the level
at which it should be set.
Merseytravel believes that Passenger Transport
Authorities (as the major transport providers in Britain's largest
conurbations) should be made formal consultees on all major planning
applications as defined by floor space triggers or any development
of more than 50 dwellings. PTAs should also be given a clear mandate
in respect of guiding the use of PGS funds, particularly around
consideration for appropriate public transport provision necessary
as a result of the development.
There are good examples where transport is already
a key consideration in the process (such as in Milton Keynes where
the Council is proposing to apply a levy on new housing schemes
at around £17,000 per unit). Merseytravel encourages the
consideration of successful arrangements such as these, that the
Government can use to inform policy development rather than inventing
a new policy all together.
Merseytravel is keen to support the PGS proposals,
providing transport needs are included as a key consideration.
If the balance of policy does not make this possible within the
current remit of the consultation, Merseytravel suggests a wider
review of planning policy, possibly to include more localised
decision-making on planning gains rather than a centralised planning
policy. There may also be scope for a strengthening of PPG13 as
part of the Government's review. If necessary, this could be included
in the current review of local government structures and impending
White Paper.
The definition of region is one that we are
particularly concerned about. In the case of Merseyside, we have
a clearly defined area upon which most people are agreed. If this,
under the plans, is extended to some concept of the North-West,
then there is no doubt that problems will occur. A definition
of region is notable by its absence in the consultation paper
and should be resolved before the PGS is progressed further.
If we take the example of the "North West",
if the expectation to recycle the overwhelming majority of PGS
funds within the region from which they are derived is carried
out then the nature of a region with two clear urban centres will
inevitably cause additional pressures. Under these circumstances
the PGS from a major building project in Liverpool could be used
to fund infrastructure in Manchester and this approach would not
be considered acceptable, especially when the problems arising
from new developments are normally localised. This goes against
established planning principles of relating benefits levied via
planning gain to the planning application that they stem from.
Whilst HM Revenue and Customs (HMRC) may be
technically well placed to administer the new scheme, we are concerned
that the correct systems are put in place to ensure that local
stakeholders decide on what projects the funds are spent. Great
care will also need to be taken to control administrative costs,
eg if the PGS funding is to go through two or three bodies before
being spent then there is an administration issue to contend with.
With PGS not due to be implemented before 2008
there is sufficient time to work this out. There is much work
on governance being undertaken by the Office of the Deputy Prime
Minister and we are engaging in this process. Given other Government
policy consultations, the reality is that there could be major
administrative changes and upheavals in Local Government structures
in the not too distant future, and so how would these impact upon
a PGS that would not be introduced until after 2008?
The "how" and "where" the
decisions are taken will be fundamental to the scheme if it is
introduced. With no level of democratic regional government in
existence with which people can readily identify, existing bodies
such as Merseytravel would be an ideal conduit to advise or administer
transport infrastructure projects, and other similar existing
bodies to advise on projects relevant to their area of responsibility.
Q2 How the supplement should reflect the subsequent
uses such as social housing.
If it is to work properly, PGS needs to be linked
to the priorities and democratic structures associated with the
LTP in respect of transport infrastructure. Developer contributions
raised through the PGS process would then need to be allocated
by the relevant local authority according to need. This would
include an appropriate amount for public transport, reflecting
public transport demands and LTP priorities.
Merseytravel's area covers five local authority
areas with varying needs. The only way we can properly balance
the needs of each of these communities—Liverpool, Knowsley,
Sefton, St Helens and the Wirral—is to engage with them
and we do this in several ways:
(a) The PTA—the Authority is made of
elected representatives of each of the five councils and this
ensures that those elected by the communities have a direct say
in the running of transport.
(b) Merseytravel Advisory Panels—each
area has its own Panel which meets quarterly. The Panels provide
a way for customers to advise Merseytravel as to how services
can better meet their requirements.
(c) Transport Access Panel—this advises
Merseytravel on how public transport can better meet the mobility
needs of people with physical or sensory disabilities.
(d) Women's Forum—this was established
to ensure women, currently the main users of public transport,
have the opportunity to influence its future shape.
(e) Merseyside Integrated Transport Forum—this
brings together key stakeholders in the Local Transport Plan (LTP).
The only effective way for decisions to be made
about the allocation of PGS monies is through engagement and consultation
with stakeholders, or by awarding the monies to bodies, such as
PTEs/As, who have already been through such processes.
Q3 How revenue from the supplement should
be distributed and appropriate uses.
The infrastructure requirement of any large
housing development has to be considered before submission of
plans. There are many examples of large scale developments that
take little note of education, health and transport needs. We
are always happy to work with developers to collaborate on transport
issues as part of major developments but many are often content
merely to consider putting a bus route through. This is insufficient,
especially given the need to integrate all forms of transport,
wherever possible; plan transport across a whole area; and given
current bus policy where de-regulation provides only very limited
power to the transport authorities for ensuring that a good quality
of service is provided.
There has to remain in place a national strategic
overview of all the infrastructure projects developed. It may
also be the case that incentives, or penalties, need to be developed
at a national level to encourage local bodies to look at the right
type of infrastructure projects.
A link between the infrastructure project chosen
and the original application from which the funding was gained
must be maintained. If the link between the investment funds and
the development is lost then it may well be seen a replacement
for state/taxpayer funding and will cause disquiet.
Any additional revenues from PGS must not be
allowed to replace existing or potential Government funding of
infrastructure projects. They must be in additional to Government
spending. Any form of replacement funding would not be acceptable
to the electorate and, we suspect, developers. PGS should explicitly
cover both capital and revenue expenditure as well.
For PGS to deliver strategic regional, as well
as local, infrastructure it will require a comparison of projects
on offer and those demanded. There are systems and procedures
in place which can help compare, for instance, competing transport
projects but this becomes much more problematic if the comparison
is across two different areas. This is to say nothing of the difficulties
involved in attempting to choose between different types of infrastructure
projects. This has to be explored in more detail before the scheme
is introduced in 2008.
Q4 The potential impact of the supplement
in s106 arrangements negotiated through the planning system.
Merseytravel believes that the suggested PGS
could be made to work as the current system has significant flaws.
Merseytravel rarely receives any of the proceeds from a section
106 agreement, even when there should properly be a large transport-related
contribution for the development to be acceptable. Too often section
106 agreements are viewed as "sweeteners" for a development
and are agreed by Council Officers and the developers before any
democratic element has entered the equation. This piecemeal approach
does not lead to strategic decisions relevant to the whole of
the area but instead encourages Officers to second guess the local
community and deliver a package of facilities that they believe
are needed. Their interpretation of local needs and the actual
needs as understood by the community may not coincide.
The relationship between PGS and section 106
agreements should be clear to public bodies from the outset. It
may be that a balance between the two is being considered. Merseytravel
believes that having two parallel methods may be confusing and
hopes this review will conclude one, new method of progressing
forward.
It is considered that government policy needs
to be strengthened so that new developments more accurately reflect
transport considerations, to ensure that sustainable and accessible
developments are created from the outset and that the costs associated
with providing transport infrastructure are shared across the
public and private sector. Merseytravel proposes in this response
a review of PPG13. This would allow even further permanence to
the responsibility of developers to contribute towards the cost
of additional public services, such as transport and the link/potential
link with s106 agreements could be explored in more detail.
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