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Memorandum by the Campaign to
Protect Rural
Introduction
1. The Campaign to Protect Rural England (CPRE) welcomes the opportunity to submit evidence to the Public Bill Committee on the Local Democracy, Economic Development and Construction Bill. The benefits of good planning have been a central interest of CPRE since our formation in 1926 and we have been closely involved in the evolution of regional planning in recent years, working both at the national level and in the regions.
2. CPRE exists
to promote the beauty, tranquillity and diversity of rural
3. Since the publication of the Government's Review of Sub-National Economic Development and Regeneration in July 2007 we have been working with our branches and regional groups to develop our thinking about the future of regional planning.
Summary
4. CPRE is concerned about the overriding economic focus of aspects of this Bill and the impact this will have on land use planning. We believe that if regional planning is to achieve the sustainable use of land, then environmental, social and economic considerations should be given equal weight. In this submission are views are focused on four main areas:
· If Local Authority Economic Assessments are to feed in to the evidence base for local and regional plans they should not be solely concerned with understanding the economic conditions of an area. Development plans should take into consideration environmental and social, as well as economic issues, and the information fed in to the evidence base should reflect that.
· Regional strategies should not simply be regional economic strategies by a different name. While we support the need for an integrated strategy, environmental issues, including climate change, should not be overlooked. Broader issues, such as the protection and enhancement of biodiversity and landscape, should also be addressed.
· The process by which a regional strategy will be developed should include meaningful engagement with local communities and stakeholders. While we do not believe the Bill should be prescriptive in this respect, it should include minimum standards that the responsible regional authorities are required to meet. In light of the significant changes that have been made to the role and remit of the Regional Development Agencies since they were created in the late 1990s, their purposes should be revised. We feel this is especially critical given their new responsibilities for regional planning.
· While we support in principle the need to enable sub-regional collaboration between local authorities, we are concerned that such collaboration could result in local communities finding it even more difficult to understand how local authorities operate and how decisions are made. We also firmly believe that Economic Prosperity Boards, which will have an economic focus, should not be able to undertake planning functions.
Local Authority Economic Assessments (Part 4)
5. We understand the new economic assessments that local authorities will be required to undertake will form part of the evidence base for local and regional plans. While we support the need for plans to be based on sound evidence, Local Development Documents and regional strategies cannot be solely focused on delivering economic development. Any evidence base for these plans, therefore, should take into consideration far more than the economic conditions of the area.
6. During the Bill's Second Reading the then Secretary of State, Hazel Blears, in response to a question by David Kidney MP, stated that 'sustainable development is at the heart of this Bill'[1]. CPRE welcomes this assurance but if this really is to be the case any assessment undertaken by a local authority should consider the environmental and social, as well as economic, conditions of its area. This would ensure that local and regional planning documents are underpinned by a balanced evidence base, therefore enabling those drawing up the plans to develop frameworks for future development that will be sustainable.
7. We believe that changes to clause 66 need to be made to ensure that assessments do not solely consider the economic conditions of an area. The Bill should require local authorities to make a balanced assessment of their area, taking into consideration environmental, social and economic conditions.
Contents of a Regional Strategy (Part 5, Clause 67)
8. In principle we support the need for better integration between spatial and economic planning and therefore a move towards a single regional strategy. The new strategies should not, however, be regional economic strategies by another name. If sustainable development is to be at the heart of this Bill the strategies should integrate environmental, social and economic considerations.
9. CPRE welcomes Clause 67, subsection (2)(a), which states that the regional strategy should set out policies in relation to 'sustainable economic growth' in the region. The term 'sustainable growth' has been used previously in Public Service Agreement (PSA) delivery agreement 7, where it is defined as 'economic growth that can be sustained and is within environmental limits, but also enhances the environment and social welfare, and avoids greater extremes in future economic cycles'. To ensure the meaning of this term is clear when the legislation is implemented we believe this definition should be placed on the face of the Bill.
10. Clause 67, subsection (4), requires regional strategies to include policies designed to 'contribute to the mitigation of, and adaptation to, climate change'. We recognise that climate change is a significant threat and regional plans should take this into consideration. It should not, however, be seen as a proxy for wider environmental concerns. CPRE would therefore like to see this subsection amended so policies in regional strategies are also required to address broader issues relating to the protection and enhancement of biodiversity and landscape.
Development of a Regional Strategy (Part 5, Clauses 68 to 84)
11. The Bill passes responsibility for regional planning from the Regional Assemblies (which are currently the designated Regional Planning Bodies) to the RDA and the Leaders' Board for the region. These bodies will be designated the 'responsible regional authorities' and have joint responsibility for developing the regional strategies.
12. We encourage the Committee to take into consideration the recommendation of the Business and Enterprise Select Committee in their report on RDAs, which stated:
'We are concerned that the proposals in the Bill about the relationship between RDAs and the local authorities place too much weight on the views of RDAs and business interests... We call for the role of local authorities - and of the communities they represent - to be strengthened.'[2]
13. Land use planning shapes how and where people live. Due to the significant impact it has on the public it is essential that it is undertaken democratically. CPRE believes, therefore, that the Committee should give consideration to the possibility of the Leaders' Forums, which will be made up of elected Councillors, having the lead role in regional planning. In these circumstance, we envisage that the RDAs, which will remain business-led and economically focused, should still be involved in developing the strategies, alongside environmental, social and economic stakeholders and communities.
14. CPRE acknowledges the inclusion of Clause 70 which requires the responsible regional authorities to undertake their work on regional strategies 'with the objective of contributing to sustainable development'. We do not however believe it is worded strongly enough to be meaningful. We feel that the responsible regional authorities should have the objective of achieving sustainable development in all that they do, not simply in relation to their work on regional planning.
15. Since the Regional Development Agencies were created their roles and remits have expanded and the Bill increases their remit even further. In the Government's consultation on proposals to reform regional planning[3] it was stated that if the RDAs were to take on new planning responsibilities they would need to undergo significant change in both what they do and how they operate.
16. We agree that significant change will be required if the RDAs are to place equal weight on economic, social and environmental considerations, as they should in their new role. We do not believe that these changes are adequately reflected in the Bill. We recommend, therefore, that the purposes of the Agencies, as set out in the Regional Development Agencies Act 1998, are amended so that they are required to contribute to the achievement of sustainable development in all the work they undertake, rather than only where it is 'relevant to its area to do so'.
17. Local communities and stakeholders have played a significant role in regional planning in the past and should continue to do so. Clause 72, regarding community involvement, requires the responsible regional authorities to 'prepare and publish a statement of their policies as to the involvement of persons who appear to them to have an interest'. Although we acknowledge that the Government does not want to be prescriptive about the most appropriate arrangements for stakeholder and community engagement we do not feel that this Clause is sufficient.
18. The Bill should be amended to include minimum standards for stakeholder and community involvement to ensure that those who have an interest in the future of their region are given an early and meaningful opportunity to feed in to the preparation of the regional strategy. Consideration should also be given to requiring the responsible regional authorities to establish and support a stakeholder body whose purpose would be to provide expert advice as regional strategies are developed and implemented.
19. The process by which the Secretary of State will approve a draft revision of a regional strategy is set out in Clause 75. The Secretary of State can make modifications to the draft strategy at this stage and as the Bill stands, has the right to determine who to consult. We believe this exclusive discretion for the Secretary of State is in contrast to the current process for the revision of the Regional Spatial Strategy (RSS). We feel that anybody should be able to contribute at this stage of the process, and it should not be at the discretion of the Secretary of State to decide who can.
20. Under the process for revising a RSS, set out in the Planning and Compulsory Purchase Act 2004, if the Secretary of State proposes to make any changes to the draft revision they are required to publish these changes for public consultation. We therefore contend that if the Secretary of State decides to modify the strategy at this stage in the process, these changes must be published for consultation so that any person can submit their views on them. These views should then be taken into consideration before the final regional strategy is published, as is currently consistent with the process for developing RSSs. We would therefore strongly support amendments that would make the appropriate changes to Clause 75.
Sub-regional collaboration (Parts 6 and 7)
21. CPRE understands the Government's desire to enable local authorities to work across their boundaries. We are concerned however that increasing opportunities for sub-regional collaboration may further confuse communities about how local authorities operate. As well as creating Economic Prosperity Boards (EPBs), which may or may not be combined with the functions of integrated transport authorities, the legislation also creates 'Multi Area Agreements with duties' to complement non-statutory Multi Area Agreements.
22. We are concerned that this push for further collaboration could result in local communities becoming even more disempowered and reduce their ability to engage in, and influence, local decision making processes. This would directly contradict the aims of other parts of the Bill which aim to secure greater involvement of the public in the workings and decision making processes of local authorities. In light of this, further consideration should be given to the need for the creation of so many different arrangements for sub-regional working.
23. We are also particularly concerned about the proposed creation of EPBs. Clause 88 of the Bill sets out powers by which the Secretary of State may allow a function of a local authority to be exercisable by the EPB and subsection (5) states that these functions should be undertaken with a 'view to promoting the economic development and regeneration of its area'.
24. If EPBs are to be created the functions that can be passed to them should be limited within the legislation. We do not believe that planning powers should be passed to EPBs. The planning system should not, and cannot, be focused solely on delivering economic growth. The aim of spatial planning, as introduced by the Planning and Compulsory Purchase Act 2004, is to widen the focus of planning beyond simply land use, not narrow it down to improving the economy.
25. The Government and this Bill must recognise the importance of ensuring equal weight is placed on economic, social and environmental issues in land use planning, and the need for democratic accountability. Clause 88 should be amended to ensure that planning is not a function that can be undertaken by EPBs rather than local authorities.
June 2009 [1] Hansard, 1 June 2009, column 25 [2] Business and [3] Department for Communities and Local Government and Department for
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