The New Local Enterprise Partnerships

Memorandum submitted by 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 the 29th 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