Written evidence from Paul Davis, Strategic
Land Director Persimmon Homes Special Projects Western
SUMMARY
1. All the current roles carried out by
RDAs still need to be carried out by LEPs and there needs to be
consistency to ensure a level playing field.
2. LEPs planning role needs to be clarified.
There is an opportunity for LEPs to prepare Sub-Regional level
plans to deal with planning issues that require guidance above
the local level.
3. The housing role of LEPs needs to be
clarified, as it is better dealt with by other bodies.
4. Guidance on the definition of LEP areas
is required to avoid overlaps and gaps and conflicts at the local
level.
INTRODUCTION
I am Paul Davis, Strategic Land Director for
Persimmon Homes Special Projects Western. I am responsible for
bringing forward strategic housing and mixed-use development sites
in the south west and Oxfordshire. I have considerable experience
of dealing with Regional Development Agencies at various levels,
relating to Regional matters and the preparation of Regional Spatial
Strategy, their planning functions in commenting on my own planning
applications, appearing against them in promoting alternative
sites and applications for various monies to support delivery
of strategic sites.
All of the roles set out above are important
and the first issue is will these roles be continued by LEPs?
The problem is nobody knows. I accept the Government's strategy
is to sweep aside existing arrangements as soon as possible and
allow their replacement through a "do it yourself" local
agreement approach, with no specific guidance from above to follow.
One of the great strengths of the former system was the consistency
it provided, ensuring there was a level playing field. This prompted
fair competition. The danger of the new ad hoc structures and
arrangements that differ from area to area is that one area could
loose out simply due to different administrative arrangements.
Whilst accepting and applauding the Government's
wish to act quickly, it is unfortunate that RDAs were swept aside
without any prior Consultation and without any real evidence to
justify such an approach, or that their replacement by LEPs would
be any better. This is compounded by the lack of guidance on how
LEPs will work, how they will deal with money, what relationship
they have with the Regional Growth Fund and how and who they will
be accountable to.
It would also have benefitted the process of
establishing LEPs if the White Paper on Regional Economic Growth
had been published when originally promised in July 2010.
FUNCTIONS OF
THE LEPS
Even if it is appropriate for LEPs to form from
discussions at the local level, there must be clear guidance on
how they should tackle specific issues they will have responsibility
for and particularly those listed in the Cable/Pickles letter
of 29 June 2010. We understand that an LEP would have a role in
creating the right environment for growth in their area, dealing
with employment issues and the transition to the low carbon economy.
But what is their role in planning and housing to be? Because
of the overlap with other Agencies carrying out both those functions
and the potential for conflicts, having included housing and planning
only within a list of potential LEP functions, it is particularly
important that their roles are properly spelt out.
LEP PLANNING ROLE
The abolition of Regional Spatial Strategy with
no transitional arrangements and no indication of the shape of
the eventual new planning system, together with the emphasis on
Localism and what are now being called the preparation of "Local
Plans", suggests that all planning would be at the "local
level". But the inclusion of planning in the functions of
the LEP, which by definition will be a group, or partnership,
of Local Authorities, suggests a tier of planning above the District
level and below the Regional level (unless an LEP was formed for
the whole of a previous Regional area).
Previously and before its replacement by RSS,
planning at the Sub-Regional level was undertaken largely by County
Councils who were responsible for preparing County level structure
plans. The Government needs to make it clear whether it is envisaged
that a similar level of Sub-Regional planning will be introduced
and that LEPs will be responsible for preparing County structure
plan style documents for their area.
Structure plans previously had an important
role to play in assessing housing and employment needs, together
with issues like transportation, waste disposal etc. This enabled
plans to look over a wider than local area without being divorced
from that local area in a way maybe the Regions were in preparing
their RSS. But they were still plans prepared by another Local
Authority separate from the District. So, LEPs preparing such
a plan would avoid this problem, as each Local District Authority
would form part of the body preparing the plan. And more than
that they would also be able to call on the expertise of business
and the private sector in putting together a fully collaborative
plan. There appears to us to be an opportunity here to produce
a workable planning system, which is necessary for co-ordination
above the purely local level to deal with issues like housing
numbers, employment land requirements, transport and infrastructure
issues etc. But it is unrealistic to expect this to emerge on
a consistent basis in the "do it yourself" way LEPs
are expected to emerge and clear guidance from Government is required
to, at the very least, establish this system and then allow specific
methods and format of plans to emerge in each LEP.
All of the above is subject to LEPs being defined
for realistic areas, for which it would be sensible to prepare
an overall plan and the geographic definition of LEPs is considered
further below.
HOUSING ROLE
Clarification is also required of the stated
housing role of LEPs. First and foremost how does this relate
to the continuing role of the HCA? It is important there is no
conflict and overlap with the HCA and there would appear to be
no reason to transfer any of the strategic responsibilities of
the HCA to LEPs. Other than that, housing is quite probably an
issue to be dealt with at the local level, or is the reference
to housing in the LEP letter related to how overall housing numbers
and the mix and tenure of housing provision is measured, so that
it is the planning aspects of housing that LEPs should be addressing.
In that case the comments above on planning apply. Again, clarification
is required.
GEOGRAPHIC CONSTITUTION
OF LEPS
We also have concerns about how the geographic
constitution of LEPs is expected to emerge without clear guidance.
Functional economic areas are usually no respecters of Local Authority
areas, so compromise can be expected. Travel to work areas and
housing market areas provide two ways of defining economic areas,
but they may conflict with each other. Again, neighbouring groups
using different basis for analysis may lead to overlaps, or even
worse gaps, where one area is left out of any LEP.
In some cases boundaries are not clear cut,
or easily defined. A Local Authority may have more than one option
of which partnership to join, but its decision could have wider
implications. An example might be North Somerset outside Bristol.
It could choose to join a "greater Bristol" partnership,
or alternatively it might join a "wider Somerset" partnership.
The implications for North Somerset of being part of an urban
based Bristol partnership would be completely different if they
were in a rural based Somerset partnership. However, clearly under
the Localism Agenda it would be for North Somerset to decide.
But how would this be done and who in North Somerset has a voice?
What would happen if political wishes were different to business
wishes? And what say do the local population have in this decision,
which may have implications for their economic futures and the
amount and distribution of development in their area?
Further questions are raised by this discussion.
How permanent will LEPs be—can an Authority withdraw at
any time? Also, can an Authority, as for example in the North
Somerset case above, be a member of more than one LEP? Clarity
on this and the other issues set out in this section are required.
13 August 2010
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