Memoranda submitted by the Royal Town
Planning Institute
INTRODUCTION
1. The Royal Town Planning Institute (RTPI)
is the largest professional institute for planners in Europe,
with over 23,000 members who serve in the public service and as
advisors in the private sector. It is a charity with the purpose
to develop the art and science of town planning for the benefit
of the public as a whole. As well as promoting spatial planning,
RTPI develops and shapes policy affecting the built environment,
works to raise professional standards and supports members through
continuous education, training and development.
2. The RTPI welcomes the fact that the BIS Select
Committee has chosen the subject of Local Enterprise Partnerships
as a subject for an Inquiry. The RTPI welcomes the concept of
LEPs but is very concerned that there is the need for more thinking
on their nature and role. The Select Committee inquiry will, we
feel, contribute greatly to that thinking.
3. The RTPI has noted the terms of reference
of the Inquiry and the topics in which the Committee is particularly
interested. In this evidence we concentrate on those aspects of
LEPs which are most relevant to our primary concerns of spatial
policy and investment and community engagement. The evidence therefore
covers:
The role of LEPs in relation to planning;
The Interrelationships between LEPs and
the existing and proposed planning systems;
LEPs and public involvement.
GOVERNMENT GUIDANCE
AND TIMING
4. Before addressing the above issues, the RTPI
wishes to raise the issue of guidance on the nature of LEPs related
to the timing for their creation.
5. The joint letter[73]
sent to Councils and business leaders from the Business and Communities
Secretaries asking them to prepare outline proposals for new local
enterprise partnerships took a de minimus approach to spelling
out the nature and purpose of LEPs. There is some guidance in
the Government's Consultation on the Regional Growth Fund[74]
which sets out the role of LEPs in broad terms but this is not
a clear guide against which outline proposals can be evaluatedif
such evaluation is to take place.
6. The RTPI fully acknowledges that this reflects
an overall stance by the Coalition Government that it is not the
role of Government to constrain innovative thinking and solutions
by prescribing the form of Government initiatives too closely
and we feel that innovative solutions may be encouraged by this
approach.
7. However, we are concerned that there is not
sufficient information against which outline bids may be evaluated;
that, in the absence of such guidance, those outline proposals
may need to be modified later; and that guidance and, perhaps,
a statutory purpose, may be published after the outline proposals
have been formulated.
8. Indeed more guidance is promised. The Government's
Consultation on the Regional Growth Fund states that:
The forthcoming White Paper, to be published
later this summer, will set out more details on local enterprise
partnerships ...
9. Additionally, LEPs are to be given a statutory
basis. The Government has stated that the main elements of the
Decentralisation and Localism Bill[75]
include: Create Local Enterprise Partnerships (to replace Regional
Development Agencies). This is reinforced in the Department's
Structural Reform Plan[76]
which states (p.14) that LEPS will be
created in the Localism Bill which is due to be passed in November
2011.
10. Given this, the RTPI wonders why it was
felt necessary to seek outline proposals within such a short timescale.
11. The statutory basis may not necessarily
include an indication of the purpose of LEPsalthough it
may be prudent to do so. It is worth remembering that, under the
Regional Development Agencies Act 1998, each Regional Development
Agency has five statutory purposes, which are:
To further economic development and regeneration;
To promote business efficiency, investment
and competitiveness;
To enhance development and application
of skill relevant to employment;
To contribute to sustainable development.[77]
12. It may well be useful for LEPs to have similarly
stated purposes against which their performance and value for
money can be evaluated. It is clear that such an evaluation process
will happen. BIS's Evaluation Strategy[78]published
in August 2010which commits BIS to: undertake a consistent
evaluation process for major departmental policies to improve
the effectiveness of evaluations and efficiency of results, states
that:
Emerging priorities for monitoring and evaluation
at this time include: Local Enterprise Partnerships (LEP).
13. Both the achievement of the Government's
wider objectives and a rigorous system of evaluating the means
by which these are achieved both demand clarity on the role and
purpose of the processes and bodies that have been established.
The RTPI believes that there is not yet that clarity associated
with LEPs.
THE SPATIAL
PLANNING ROLE
OF LEPS
14. The joint letter sent to councils and business
leaders from the Secretaries of State for BIS and CLG asking them
to prepare outline proposals for new local enterprise partnerships
stated:
Partnerships will ... want to create
the right environment for business and growth in their areas by
tackling issues such as planning and housing, local transport
and infrastructure priorities, employment and enterprise and the
transition to the low carbon economy.
15. As has been seen, this has been reinforced
in the Government's Consultation on the Regional Growth Fund
which states that:
We are keen to understand how you envisage
local enterprise partnerships interacting with local authority-led
decisions, particularly where they impact significantly on the
economy, for example on planning, transport, housing and local
asset management.
16. The RTPI very much welcomes this encouragement
to those putting forward outline proposals to include some form
of planning function in those proposals and we view this stated
link between business and growth and planning as being crucial
in attempting to (re)establish integrated relationships between
spatial planning and economic development.
17. Indeed, we cannot see how LEPs can fulfil
their main stated function:
to provide the strategic leadership and long-term
vision for the private sector-led economic renewal of their area[79]
without a clear understanding of the role of
spatial planning in achieving economic renewal and development.
The coordination of separate but adjoining local authorities for
the purposes of addressing issues of future growth and development
is surely one of their key raisons d'etres.
18. Given this, we find it disappointing that
an even greater emphasis is not given to the role of LEPs in terms
of planning. Added to this, and equally importantly, it is clear
that there will not be complete coverage of England by LEPs. One
estimate[80]
at the end of July was that there may be some 40 LEPs. Thus, significant
parts of the country will be left without the benefits of LEPs
and will have to achieve "strategic leadership and long-term
vision" through other, more ad hoc, means. If there is not
national coverage, some parts of the country will be at a disadvantage
(regarding public investment) and their strategic planning issues
(if addressed at all) may well be taken on by national government.
19. In this context, it is worth noting that
the forthcoming White Paper will be looking at the overall role
of planning in relationship to investment and growth. BIS's Strategy
for Sustainable Growth[81]
states that:
With Communities and Local Government (CLG)
and HM Treasury, we will be publishing a White Paper on sub-national
growth. ... It will ... set out the Government's approach
to improving incentives for local economic development [and] increasing
the ability of the planning system to support investment and growth ...
20. For all these reasons, the RTPI strongly
believes that the vacuum left by the revocation of Regional Spatial
Strategies (RSSs) and intended abolition of them and of the Regional
Development Agencies, Regional Leaders' Boards and Government
Offices for the Regions has not been filled by Local Enterprise
Partnerships and that it is disingenuous for Government to suggest
that LEPs in some way "replace" RDAs.
21. Instead, the RTPI hopes that the further
guidance promised in the forthcoming White Paper will set out
aspects of these new relationships in a positive and constructive
way.
22. Whether or not this is their stated aim,
LEPs will, and need to, provide strategic guidance for local development
framework preparation. Without this there is a real danger of
individual core strategies becoming incremental and uncoordinated.
The "vision" is necessary because small scale LA areas
do not function in isolation from one another and there is a real
need to coordinate the provision of infrastructure, plan to limit
commuting, protect and improve the environment, share community
facilities and ensure an adequate supply of housing.
23. It may be desirable in some places for LEP
plans to have a statutory basis in forming a joint LDF core strategy
leaving individual Local Planning Authorities to produce neighbourhood
or Area Action Plans (eg the legislation for LEPs could be set
up with the intention of enabling appropriately constituted LEPs
to act as the joint committees for the purposes of preparing joint
core strategies). However, this would need proper consideration
both in the drawing of LEP boundaries and in framing legislation.
24. Just as it is important to be be clear about
the overall role of LEPs in relation to spatial planning and investment
(the next section of this evidence covers the interrelationships
inherent in this role), so there is the need to focus on specific
aspects of that role. Two examples may suffice to illustrate this
point.
25. First, it is recognised that one of the
drivers for private sector-led economic renewal and development
is the existence and the encouragement of spatially based "clusters"
of particular industries and of the skills and knowledge support
that they require. Such clusters will include, for example, aerospace
and medical industries.[82]
BIS currently recognises that:[83]
In England, the RDAs are pivotal players in
facilitating the development of clusters, working closely with
local authorities, trade associations and business bodies and
providers of education, training and research.
26. It is not clear howor whether this
"pivotal" role will be played by LEPs or, indeed, whether
the geographical boundaries of the putative LEPs will be aligned
with the optimum area to support such clusters. If it is not,
then this will be a wasted opportunity.
27. The second example is the role of planning
at the sub-regional level to promote the highest quality for significant
economic development. At present most RDAs support (at arm's length)
an independent design review process in relation to regionally
significant planning applications. This function is under threat
because the funding will be lost and local authorities (whether
in LEPs or not) do not have the resources, expertise or independence
to undertake this function. This is another area in which an LEP
as promoter of high-quality sustainable economic development should
have a clearer and more explicit role.
RELATIONSHIP OF
LEPS TO
THE EXISTING
AND PROPOSED
PLANNING SYSTEM.
28. Whilst an LEP for a single local authority
area is not ruled out, the great majority of LEPs will occupy
a position in terms of planning and spatial investment between
local and national planning.
29. In this case, planning and spatial investment
are seen in their widest sense to include at the local and sub-regional
levels; Local and Multi Area Agreements, Sustainable Community
Strategies, Local Transport Plans, Local Housing Strategies and
initiatives such as local infrastructure delivery plans, Total
Place and place-based budgeting. There is also the need for LEPs
to establish a relationship with existing statutory bodies including,
for example, Integrated Transport Authorities and Infrastructure
UK (I-UK).
30. At national level, it will include the Government's
proposals for National Planning Framework (included in the Coalition
Agreement, published on 20 May 2010)[84],
a National Infrastructure Plan (announced in the 22nd June 2010
Budget Report,[85]
para 1.83) and a range of existing national policies.
31. For example, DEFRA launched a consultation
on a natural environment White Paper on 26 July 2010[86]
and of waste policy on 29 July[87]
and the Department for Business, Innovation and Skills (BIS) published
A Strategy for Sustainable Growth[88]
on 20 July 2010. Additionally there are
a number of extant national policy documents for these areas from
the previous administration including, for example:
The Government's 2009 The UK Low Carbon
Transition Plan: National strategy for climate and energy;[89]
The 2009 UK Renewable Energy Strategy
Consultation;[90]
The Department for Transport's 2008 Delivering
a Sustainable Transport System;[91]
and 2010 High Speed Rail documents;[92]
and
DEFRA's 2008 Future Water: The Government's
Water Strategy for England.[93]
32. It needs to be borne in mind that LEPs will
be appropriate for some levels of infrastructure planning but
not all. For example major roads and other transport infrastructure
is best planned at a national level in the National Planning Framework,
whilst primary health care, education and skills, local transport
(including public transport), higher level recreation facilities
are best planned at the sub-regional level.
33. In highlighting these relationships, the
RTPI is not advocating a complex hierarchical system of policy
making. Nor is it arguing for a return to a past system. Before
the 2010 General Election, the RTPI had already stated in its
Manifesto for Planning[94]
that:
We need plans above the local level to deliver
development and infrastructure that crosses administrative boundaries,
but there is a lack of faith in the current system of regional
planning. ...There must be strategic plans for meaningful
areas at the wider than local scale, that relate to the areas
in which people live and work and to natural ecosystems, to enable
options to be considered and conflicts resolved in an open and
accountable manner.
34. Instead, we are pointing it out that it
is clearly very important to understand the relationship between
different existing and proposed types of planning policy making
and to ensure that LEPs serve as an integral means of achieving
both the Government's and local communities' aspirations and agendas.
It is equally important to ensure that the same tasksuch
as local infrastructure planningis not being undertaken
by different bodies working to different priorities and goals.
35. However, once again the RTPI looks in vain
for any encouragement for those proposing LEPs to demonstrate
how they will work within an existing planning and investment
system or relate to the Government other proposals and, importantly,
how they will add value to that system.
COMMUNITY ENGAGEMENT
IN LEPS
36. Successful localism is inextricably linked
to successful community engagement. This means balanced and inclusive
engagement with all those in a neighbourhood or wider area. The
community need to be able to influence not only local politicians
but those charged with responsibility for the economic future
of their areas.
37. Community engagement will not provide all
the answers to the economic issues facing an area, but it will
enable the community to identify those aspects which are of greatest
concern to them and the solutions they feel will best fit their
local circumstances and is at the heart of a localism approach.
38. Transparency and accountability will, therefore,
be key requirements for a successful LEP. The LEPs need to work
co-operatively with local people to develop credibility and trust,
which in turn will feed through to more flexible and creative
responses to the economic and other matters which the LEPs are
to be tasked with tackling, and in doing so provide a stable foundation
on which to manage future change and uncertainty.
39. Since the Skeffington report People and
Planning was published in the late 1960s[95]
there has been a widespread acceptance that community engagement
in planning brings real benefits to the process. Since then there
has been a steady growth in public engagement in the planning
system and other areas of public service provision. The "localism"
agenda takes this engagement a step further and has raised strong
expectations in local communities about the extent of influence
which they will be able to exert upon decision makers and decision
takers.
40. If the LEPs are to become involved in the
development of a long-term vision, then there is a need to ensure
that the communityincluding the "hard to reach"
and disadvantagedhave an opportunity to comment on and
shape the future of planning policy within their areas. Local
communities will have also very clear views on the infrastructure
priorities within their area and how they would prioritise its
delivery. These views need to be captured and reflected in the
decision making processes and connected with decisions on housing,
transport etc, with the connections being made clear to those
who are consulted.
41. There will be a need for each LEP to work
with the local communities and businesses (small and large) within
their area to understand the issues which they face with regard
to matters such as access to work, availability and suitability
of premises, skills etc. In particular, for those who are economically
disadvantaged or excluded, there is a need to explore with them
solutions which deliver a longer term sustainable future. Exclusion
not only has a significant adverse economic impact, but also negative
social effects with unemployment directly linked to increased
poverty, poor health and low educational standards.
42. To achieve real engagement there is a need
for the LEPs to recognise that it is often necessary to build
social capital through the provision of knowledge and skills in
the most disadvantaged areas before genuine and inclusive engagement
can happen. In doing this they will not only assist in realising
the aspirations articulated through the "localism" changes,
but in doing so leave behind a community better placed to realise
its social and economic potential.
43. Given all this, the RTPI considers it regrettable
that neither the joint Secretaries of States' letter nor the description
of the roles of LEPs in the Growth Fund consultation mention the
role of the communities in shaping and being part of implementing
the long-term vision called for. We will look to the forthcoming
White Paper to rectify this omission and to demonstrate that the
concept of localism, which is stated to be at the heart of the
Government's agenda, applies equally to economic policy and development.
CONCLUSION
44. The RTPI is positive about the potential
inherent in Local Enterprise Partnerships for integration and
for setting out and helping to implement a vision for the economic
development of different areas. We are pleased that such guidance
as does exist does state the need to look at the roles that LEPs
should play in terms of planning, transport and housing.
45. However, in this evidence, we raised a number
of issues which remain unclear and on which there is the need
for greater thought and advice. One conclusion from this evidence
is that the current (at the time of writing) call for outline
proposals for LEPs may be premature in advance of responses to
the consultation on the Regional Growth Fund, the further guidance
promised in the White Paper and, even, in advance of the draft
clauses related to LEPs in the Decentralisation and Localism Bill.
46. The RTPI recognises that the outline proposals
received by the Government may well inform further guidance and
the nature of the statutory basis for LEPs but, we feel that such
thinking may have been better generated by Government engagement
and consultation with stakeholders and community groups on this
specific proposal. Given this, we look forward to the recommendations
arising from this very welcome inquiry by the BIS Select Committee.
47. The RTPI would be pleased to add to and
elucidate any of the points made in this evidence, either in writing
or in oral evidence to the Select Committee.
16 August 2010
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