APPENDIX
IED RESPONSE TO SNR CONSULTATION
Q1. How should RDAs satisfy themselves that
sufficient capacity exists for programme management and delivery
at local or sub-regional level?
IED accepts that SNR requires both local authorities
and RDAs to considerably raise their capacity and adapt their
roles. On the other hand many local authorities deliver and manage
multi-million pound projects on a regular basis and are well capable
of handling additional responsibilities.
Local authorities will generally have to increase
their strategic policy and delivery skills, while RDAs will need
a new capability in regional planning and community engagement.
Both will also need to support the further development of sub
and city region working.
RDAs and local authorities already work closely
together on a day to day basis on the delivery of effective regeneration
and therefore have a good idea of each other's capabilities and
limitations. To supplement this appreciation work is already underway
in some regions to systematically evaluate capacity and we would
commend this. We would suggest that it be closely linked to the
future activities of Regional Centres for Excellence for Regeneration
(RCEs), the work of the Regional Improvement and Efficiency Partnerships
(RIEPs) and the Academy of Sustainable Communities.
A key principle that needs to be adhered to
is transparency in dealings between RDAs and local government.
This will particularly need to be applied to the designation of
appropriate areas for functional devolution of responsibility
and capacity assessment. In parts of the country where local authorities
and RDAs work less well together, this should form the basis of
partnership working to increase their collective capacity to deliver.
IED is convinced that considerable capacity
already exists within the system and it is willing to commit itself
to working with the RCEs, RIEPs and other professional bodies
to upgrade this. With the imminent creation of the new Homes and
Communities Agency (HCA) we would particularly identify the need
to link economic and housing regeneration agendas.
Q2. Do you agree that local authorities should
determine how they set up a local authority leaders' forum for
their region, and that the Government should only intervene if
the required criteria are not met or if it failed to operate effectively?
If not, what would you propose instead?
Yes, IED supports the principle of subsidiarity
and greater devolution of powers and resources to local, sub-regional
and regional bodies as they increase their capacity and establish
clearer lines of accountability to the communities they serve.
We do however recognise that this is easier
in some regions than others, simply because in some there are
10-20 councils and in others 60 plus. We believe the Government
should consider funding a small directorate or secretariat in
each region to assist this forum.
Q3. Are the proposed regional accountability
and scrutiny proposals proportionate and workable?
As set out in the consultation document this
promises to be an iterative process, and we would therefore agree
that they are appropriate at this stage, but will need much more
clarity as the agenda unfolds. IED has members in RDAs as well
as local authorities and we therefore recognise there is a danger
of them being forced to face two ways at once. There should be
a clear distinction in the national and regional local accountabilities—the
former should be in relation to audit, propriety organisation
and performance, the latter should be about policy, equity and
delivery of outputs and outcomes in relation to the IRS.
Q4. Do you agree that the regional strategy
needs to cover the elements listed at paragraph 4.13? Are there
other matters that should be included in the regional strategy
to help in the delivery of key outcomes?
We would not wish to be too prescriptive at
this stage given our earlier comments, but a number of our members
felt more sustainability criteria should be considered to counterbalance
the stress on GVA. In addition, we would ask that a Government
contribution be considered to set out the following:
— the distinctive role that each region
might be expected to contribute to the national well-being,
— a statement of how the IRS related
to other existing regional strategies,
— a summary of relevant regional aspects
of the skills agenda (especially as it relates to FE and HE provision),
— a statement of national transport
priorities as they affect the region, and
— a list of any other major infrastructure
and other commitments that will assist in achievement of the strategy.
Q5. Do you agree with the way in which we
propose to simplify the preparation of the regional strategy,
as illustrated in the figure (on page 35), in particular allowing
flexibility for regions to determine detailed processes? If not
what other steps might we take?
We welcome the clarity of this process and its
potential timescale. We would however point out that previous
commitments to streamlining planning processes—from structure
plans to local development frameworks—have largely not been
met. Our members would generally point to the amount of detail
and prescription previously required as major stumbling blocks
and would urge a firm commitment to the principles of subsidiarity.
We would also advocate the recognition of sub-regional priorities
as building blocks of the IRS where these have been agreed.
Q6. Do you think that the streamlined process
would lead to any significant changes in the costs and benefits
to the community and other impacts?
IED, through its working with public and private
sector, recognises that the planning process is not held in high
regard. We recognise however there is always a tension between
democratic accountability and the desire to speed up the process
especially for significant development proposals. It is however
accepted that too many important proposals have far too many hurdles,
despite many Local Planning departments showing much improved
performance.
A streamlined process that works would go a
long way towards re-establishing the credibility and commitment
which is a natural prerequisite of a successful system.
Q7. Which of the options for the local authority
economic assessment duty (or any other proposals) is most appropriate?
From our previous statements IED would generally
advocate maximum local flexibility, although we also see the merits
of having reasonable guidance on what might be considered appropriate
in a local assessment. We do not however see the merit in such
guidance being statutory, as we suspect that local authorities
will be only too willing to comply with sensible advice, not least
in order to increase their credibility, and we therefore favour
option 2.
Q8. What additional information or support
do local authorities consider valuable for the purpose of preparing
assessments?
We would echo our comments in Q1 above. Support
for such work should be a priority for the future activities of
Regional Centres for Excellence in Regeneration (RCEs) and the
work of the Regional Improvement and Efficiency Partnerships (RIEPs).
We would also urge consideration of support from RDAs and the
Government for developing sub-regional partnerships to assist
this capacity.
Q9. How should lead local authorities engage
partners, including district councils, in the preparation of the
assessment?
We would advocate local cooperation to determine
these issues, with perhaps a simple requirement for statement
of involvement, similar to that required for LDFs etc. RDAs or
Government Offices should offer assistance if local partners are
unable to agree.
Q10. Which partner bodies should be consulted
in the preparation of the assessment?
Local authorities are well used to involving
a wide range of local partners, but typically these should include:
— The LSC or successor bodies
— Local HE and FE providers
— Neighbouring local authorities
— Key Community and Voluntary Sector
organisations
— Local private sector representatives
We would additionally urge that the RDAs and
RCEs consider a possible mechanism for high level private sector
involvement in local assessments, perhaps by facilitating contact
with strategically important private sector partners.
Q11. Should any duty apply in London and,
if so, which of the proposed models is most appropriate?
We feel that the London area should be able
to determine its own structure in the same way as the rest of
the Country.
Q12. Do you agree that there is value in creating
statutory arrangements for sub-regional collaboration on economic
development issues beyond MAAs? What form might any new arrangements
take?
Yes, subject to the principles of subsidiarity
we would advocate the potential creation of economic and planning
sub-regional partnerships where there is a local desire to see
them, where is going to be recognisable added-value and where
there is a track record of successful cooperation.
Q13. What activities would you like a sub-regional
partnership to be able to carry out and what are the constraints
on them doing this under the current legislation?
IED would not wish to be prescriptive at this
stage, but it can see a current desire in some regions for partnerships
which would be able to deliver on a wide range of economic issues,
including enhanced communications, skills provision, bringing
forward employment land or serviced space and access to employment
sites, affordable housing environmental schemes and waste provision.
Q14. How would a sub-regional economic development
authority fit into the local authority performance framework?
There are parallels with the way in which CPA
currently takes into account the activities of LSPs and other
partnerships outside the sole control of local authorities. Where
MAAs are pursued then appropriate performance criteria will be
agreed, but other than this we would ask why the performance frameworks
should be part of the current local authority framework?
Q15. Should there be a duty to co-operate
at sub-regional level where a statutory partnership exists? To
whom should this apply?
No we do not believe this makes a significant
contribution and we rarely have examples of local partners not
being able to cooperate where they have common objectives given
the appropriate resources.
30 June 2008
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