Abolition of Regional Spatial Strategies: a planning vacuum? - Communities and Local Government Committee Contents

Written evidence from Merseytravel (ARSS 123)

Please find enclosed Merseytravel's response to the above Communities and Local Government Committee inquiry.

Merseytravel is the combined Passenger Transport Executive (PTE) and Integrated Transport Authority (ITA) for Merseyside, and is the public sector body responsible for the coordination of public transport across the Liverpool City Region (including Liverpool, Sefton, St Helens, The Wirral and Knowsley, with the exception of Halton). Working with our partners across the local authority districts and the business community, our objective is to produce a fully integrated public transport system which is accessible to all.

Merseytravel supports the Coalition Government's localist agenda and the focus that it is placing on facilitating economic growth and the development of the private sector across the country. Transport is a central part of these efforts and, in particular, a lack of accessible and efficient transport links present a real barrier to economic growth and investment, as well as impacting on social inclusion and the challenge of reducing carbon emissions..

As you know, Regional Spatial Strategies were introduced by the Planning and Compulsory Purchase Act 2004 but, as of 1st April 2010, were replaced by the single Regional Strategy (consisting of the existing Regional Spatial Strategy and the Regional Economic Strategy until the Regional Strategy was adopted), under the Local Democracy, Economic Development and Construction Act (LDEDCA) 2009.

The Regional (Spatial) Strategy is, of course, part of the statutory Development Plan, in line with which planning decisions must be taken unless material considerations indicate otherwise. As the Strategy decides how much development there should be, how it will be spread around each region and how it will be delivered, it affects not only housing but also infrastructure, transport, the environment and economic development to name but a few. As such, despite its faults, the Strategy was of great significance to the future of local areas.

Merseytravel is a strong proponent of the need for a mechanism to ensure co-operation between local authorities and other bodies, in particular ITAs, on important regional-level issues like transport. As such, this submission addresses the abolition of the Regional (Spatial) Strategy and its connectivity to transport.


We support the localism agenda and the bottom-up approach that is being advocated.

However, we would urge for greater clarification in what happens to responsibilities following the dismantling of the regional tier of Government.

We also suggest that the ITA/PTE model is looked at as a successful example of a bottom-up model that allows local authorities to come together with other stakeholders to address shared challenges surrounding transport services and infrastructure.

We are concerned that, with the abolition of regional house building targets, there needs to be certainty about where housing will go so that the necessary associated infrastructure can be provided.

For matters such as transport, it is important that the Coalition Government's new planning arrangements acknowledge and address that transport covers the area or parts of the area of more than one local authority.

Local Enterprise Partnerships (LEPs) should be designed in response to local requirements and, where appropriate, should complement and build upon existing structures and established working practices, for example ITAs since they already work so well.


2.1  Merseytravel is the combined Passenger Transport Executive (PTE) and Integrated Transport Authority (ITA) for Merseyside. It is the public sector body responsible for the coordination of public transport through partnership initiatives, doing so with the aim of producing a fully integrated and sustainable transport network which is accessible to all.

2.2  Merseytravel operates at the level of the Liverpool City Region, largely reflecting functional economic areas and operating at the optimum strategic level for the provision of transport. The ITA/PTE model is a highly successful example of a bottom-up model that allows local authorities to come together with other stakeholders to address shared challenges around the provision of transport services and infrastructure, and to support policy objectives around economic development and regeneration, health and climate change.

2.3  Merseytravel has responsibility for producing and implementing the Local Transport Plan (LTP), which is the key policy framework for transport. Transport issues are of central importance to the development of regions. Merseytravel has long argued that transport must be considered within a wider context, linking with other policy areas such as economic development and regeneration, carbon reduction, housing and land use planning, skills, education and health. Focussing not just on the passenger transport network, Merseytravel has played a key role in investing in infrastructure that directly supports economic investment, or maintains key transport arteries.

2.4  We agree with the Coalition Government's position that "planning decisions should be made at the local level wherever possible". However, we would stress that as consideration of transport issues has to be at the heart of the economic revival and of regeneration, the planning system should include ITAs as statutory consultees in the planning process so that councils can make more informed decisions in the best interests of their local area. Whilst supporting the principle of localism we also note the importance of a strategic approach to decision-making in the correct circumstances.

2.5  There needs to be a balance between the need to stimulate economic recovery and the long-term requirements of a successful development as far as the local community is concerned. These are not mutually exclusive and full and proper consideration of transport matters in local planning can deliver a better development of benefit the local community, the local authority and the developer.


3.1  Within the Regional Spatial Strategy framework (or Regional Strategy framework following the LDEDCA 2009) sat the Regional Transport Strategy (RTS) and, therefore, the Coalition Government's announcement to revoke Regional (Spatial) Strategies also includes the revocation of RTS's.

3.2  The North West RTS provided the transport policy framework for the North West of England, including Merseyside, and encouraged close integration between regional transport, housing, economic development strategies and spending decisions.

3.3  The key objectives of the RTS were to:

maintain existing transport infrastructure in good order;

improve journey time reliability, tackle congestion and overcrowding in the region's main;

transport corridors shown on the Key Diagram, particularly within and between City Regions;

secure a shift towards the use of more sustainable modes of transport;

secure safe and efficient access between residential areas and key destinations, including centres of employment, schools, shops and other services;

improve surface access and interchange arrangements at the international, national and regional gateways;

reduce the adverse impacts of transport, in terms of safety hazards, climate change, environmental degradation, residential amenity and social exclusion; and

integrate the management and planning of transport systems.

3.4  The RTS also identified a number of strategic transport management and investment priorities for the region, in order to help deliver the wider spatial strategy.

3.5  The RTS policies supported the vision and objectives of the Regional (Spatial) Strategy by concentrating on the development of better transport links within the region, and between the North West and other parts of the UK and beyond. They aimed to do this by significantly improving the quality and provision of public transport and by promoting a more structured approach to managing and selectively improving the region's highway network. In doing so, the policies aligned with the Regional Economic Strategy objective to develop the North West's strategic transport, communications and economic infrastructure, and with the policy priorities of the Northern Way Growth Strategy, particularly in terms of improving road and rail access to the North of England's main ports and airports and creating better integrated public transport services within and between City Regions.

3.6  In addition, the RTS set out the need for a sustainable approach to integrated transport, which requires each mode to contribute to future travel needs in an efficient and complementary way. The RTS emphasised therefore that local authorities, the Highways Agency, the rail industry and other transport providers needed to work together to ensure that all of the region's transport networks are planned, managed, operated and improved in an integrated context.

3.7  Accordingly, the abolition of the Regional (Spatial) Strategy means that LTPs will be the only main statutory policy framework covering the sub-regional level. This means that the proposals put forward by the Coalition Government (for example, LEPs or the duty to cooperate) and their remit in contributing to the LTP process will have to be clearly defined.

3.8  In addition, whilst Merseytravel has sole responsibility for Merseyside's LTP, the removal of the RTS means that there is an increased danger of LTPs across the North West, and in other areas, been seen to 'compete' against one another. One way to deal with the issue of possible competition would be for central government to adopt a strong role in providing direction for the plans, monitoring them and exercising control in their development. We appreciate this goes against current thinking from the DfT on how LTPs should be prepared, and would require more consideration about how such control could be implemented in practice, but ways of preventing competition need to be instigated.


4.1  The Government has indicated that local authorities should continue to ensure their land use and local transport plans are mutually consistent, and deliver the most effective and sustainable development for their area. Moreover, local authorities should work with each other and with businesses and communities to consider strategic transport priorities and cross boundary issues.

4.2  We fully support the Coalition Government's localism agenda but, in our view, localism cannot be a substitute for a proper national and sub-national approach to the coordination of economic regeneration and development. The abolition of the regional tier of Government gives rise to a number of issues which are of concern to Merseytravel. Some of these may be addressed in the development of LEPs and Merseytravel has been fully engaged in discussion around a LEP for Merseyside. There are though obvious timings issues as the Regional (Spatial) Strategies have already been abolished whereas it may take some time to have a fully formed LEP up-and-running. Concerns remain that LEPs will not be a completely satisfactory replacement. A strategic approach to development is even more important in a financially constrained environment.

4.3  Our first issue of concern is that the absence of a strategic planning model at a sub-national level particularly for land use and housing targets is of concern. Despite their obvious faults, Regional (Spatial) Strategies did at least give the opportunity to explore sub-national planning issues and coordinate activities across regions. Following the abolition of Regional Strategies, as we have already mentioned, the only remaining statutory plan for coordinating activities above the district level remains the LTP.

4.4  The second issue of concern is that the abolition of the regional tier and the potential replacement with the LEP model may give rise to groups of local authorities competing nationally against each other for access to investment and funding. Such an adversarial approach might not necessarily provide for the most constructive overall outcomes as far as the delivery of economic and social regeneration and environmental objectives is concerned. There is also a risk that such competition might actually increase costs. The abolition of the Regional Funding Allocation (RFA) with spending decisions based on the challenges and problems identified in the Regional (Spatial) Strategy has meant the danger of competition for funds has increased.

4.5  Related to this, if the administration and awarding of funds is simply moved back to Westminster and Whitehall, and away from the regional level then this would appear to run counter to the aims of localism. Without the RFA it appears that local authorities will seemingly need to apply direct to central government for finance and/or approvals.

4.6  Accordingly, we contend that a system needs to be devised which allows strategic thinking beyond the local level to deal with transport. ITA areas at least benefit from covering larger geographical areas, whereas in many other parts of the country the responsible local transport authority may cover quite small areas.

4.7  As the RTPI has quite rightly stated "Communities need some level of strategic thinking beyond the local level to deliver the things they need, such as hospitals and transport links".


5.1  It is not Merseytravel's place to comment on the abolition of regional house building targets. However, if there is no certainty about where housing is going to be developed then this does impact on decisions about the necessary infrastructure to be provided. Especially at this time when LTP3s are in the process of development such uncertainty is unwelcome.

5.2  Accordingly, we suggest, the Coalition Government needs to develop a planning system which crosses local authority boundaries so that the localism agenda does not curtail strategic planning across regions. We believe that ITAs should be statutory consultees in any reform of the planning system proposed under the forthcoming Localism Bill.

5.3  The RTPI has said that there is a "need to limit any adverse impacts that the abolition of Regional Strategies may have on investment (in transport particularly)". We agree with this position and believe that the Coalition Government needs to provide more details on the replacement from the regional planning level as a matter of priority.


6.1  We understand that local communities are to receive direct and substantial extra funding to spend as they wish as a reward for growth, including a "New Homes Bonus" for those local authorities who give planning consent and support the construction of new homes where they are needed. There are some potential pitfalls associated with this approach as it could incentivise house building in the most popular and/or economically buoyant parts of the country rather than those parts of the country facing challenges as a result of housing market decline, which affects large parts of the North West in particular. This could mean rewards for already successful areas but stagnation for others. In transport, further decline of inner city areas, for example, could undermine the vitality of existing transport provisions and any strong pressure for housing in inaccessible rural, or semi-rural, areas could create new transport pressures as a result on increased car dependency.

6.2  We also understand that the Coalition Government is working on business rate reforms to encourage economic development, as well as reforming the Community Infrastructure Levy to provide development incentives.

6.3  We would welcome the opportunity to respond to the Government's consultation paper on the final incentives scheme, which we understand is to be published following the spending review.

6.4  Whilst we also welcome the opportunity to incentivise local communities, the Coalition Government needs to make sure that there are sufficient funds to incentivise local infrastructure as well. At the present time incentivisation appears only to apply to supply in one sector (housing) and needs to be looked at and developed across other sectors, such as transport infrastructure.

6.5  The lack of a current formal role in local development decisions means that in ITA areas new development could take place without due regard being given to transport infrastructure requirements. This is a risk which is heightened if an overly competitive approach to development, particularly housing development, is adopted. For instance, it could that local authorities try to attract developers by minimising the contributions they need to make to infrastructure development, particularly transport.

6.6  One safeguard would be to make ITAs statutory consultees in local development control decisions.


7.1  For matters such as transport, it is important that the new arrangements acknowledge and address that transport covers the area or parts of the area of more than one local authority.

7.2  The previous arrangements meant that local transport authorities, including ITAs, could work together on a set of policies decided at the regional level. This, alongside the system of the Regional Funding Allocation, although imperfect, prevented competition between local transport authorities.

7.3  The abolition of the regional arrangements now means that there is no formal process for such cooperation to take place. Instead, it relies on the goodwill and professional integrity of those involved.

7.4  The establishment of LEPs may be one way forward but with details currently lacking on their shape, form, powers and funding this remains more of a hope than certainty. LEPs may prove to have a very valuable role at local level but, again, their ability to work across larger geographical areas, either together or on their own, is not clear.


8.1  As mentioned above, from the details about LEPs made available to date, they appear to provide for an interesting model through which to ensure coordination on economic development and related challenges, including transport. Any approach to partnership working, policy making and delivery that allows particular challenges to be address at the most appropriate spatial level is to be welcomed.

8.2  We welcome comments from Ministers that it is for the local authorities and businesses involved to set out how LEPs should be comprised and operate. However, much more information is required on their form and function and specifically on how it is expected that they will operate alongside existing non local authority bodies, such as PTEs/ITAs. We appreciate that in many ways this is will be decided locally and we are pleased to be involved in discussions on the establishment of a LEP in Merseyside.

8.3  LEPs should be designed in response to local requirements and, where appropriate, should complement and build upon existing structures and established working practices. Given the need to manage public spending effectively, going with the grain of existing arrangements, such as PTEs and ITAs would seem sensible.

8.4  We would therefore suggest that LEPs should be designed around, and seek to complement the strengths of, existing models of cooperation and established joint working. This is particularly important at a time of reduced public expenditure where going "with the grain" of existing arrangements is likely to be more efficient than creating wholly new structures to replace what is already happening.

8.5  Consideration of transport issues has to be at the heart of the economic revival and regeneration and a LEP approach may provide a real platform to drive regions, forward afresh, ensuring that all the key stakeholders are properly involved.

8.6  Within the Liverpool City Region context, the North West Development Agency has done some important work in recent years; however obviously RDAs will not continue in their current form and with their current functions. With the Government Offices also being abolished and with indications that the Government's preference would be for models of partnership involving local authorities and other stakeholders, particularly the business community, rather than more formalised or statutory structures, we agree that regions should consider the opportunities that forming an LEP will provide.

8.7  There is no prescriptive model as to what an LEP should look like and what it might do. We understand that they are intended to be "bottom-up" bodies created to address the economic challenges identified by groups of local authorities in conjunction with the business community, building on and complementing those existing structures and working practices that have been proven to work well.

8.8  Significant issues around LEPs remain to be addressed, not least around governance, their powers, the involvement of the business community, and how they will work with existing organisations. We understand that further information will be provided in the White Paper on sub-national economic development expected in late September or October 2010 but by 6 September the Liverpool City Region needed to submit its outline proposal for its LEP to the Government, if that is the chosen option.

8.9  Transport has to be a central consideration within the LEP. For the Liverpool City Region, this will require discussion and agreement amongst the six local authorities, the business community, Merseytravel, the North West Development Agency, organisations such as The Mersey Partnership and Liverpool Vision, and possibly also the fire, waste and police authorities. In this way an LEP can be viewed as a "wrap around" body bringing existing organisations and expertise together in a way which provides additional private sector input to deliver on the economic, social and environmental aims of the LCR. The ITA would have a central role in these arrangements.

8.10  LEPs of course will also need to be considered in the context of policy development in a wide range of other areas, not least the review of local government finance and the ongoing spending review, proposals for city mayors and issues across education, work and skills and health.

8.11  We would also welcome further details about the mechanisms that will be put in place to ensure cooperation between LEPs and between LEPs and individuals in local authorities and bodies, such as PTEs/ITAs, would be ensured, including how this relates to the proposed duty to cooperate.

8.12  There needs to be greater clarity over the distribution of the funding, powers and responsibilities held at a regional level, and how these will be redistributed once LEPs are in place. More specifically, if LEPs are not to have a statutory basis then further information will be required as to how the statutory functions of the RDAs and Government Offices (GOs) will be discharged, if they are to be retained. It is not clear by what mechanism the functions of RDAs and GOs will be redistributed following the creation of LEPs. We are concerned to ensure that the excellent work done by the RDA and Local Authorities Leaders Board is not lost.

8.13  Whilst we welcomes the idea of LEPs in principle, we are concerned to learn that the Coalition Government has said they are to be business-led; handing planning over to businesses, we suggest, is not in keeping with the localist agenda. It can be difficult for a private sector led planning system to take strategic (and often difficult) decisions that locally accountable bodies are able to make.

8.14  If the Coalition Government expects LEPs to be business-led, further information is required as to how accountability will be ensured. This is particularly pertinent given the criticisms levied at RDAs in this regard. In addition, how LEPs will interact with elected mayors, whether these are for the city councils or for city regions will be a central consideration.


9.1  The status of measures such as the Duty to Co-operate remains unclear. Whilst it may be useful in helping to facilitate relationships between LEPs, this requires clarification.

9.2  Consideration also needs to be given as to how the new structures and bodies will comply with the requirements of the new Equalities Act.


10.1  Merseytravel believes that the sudden abolition of the Regional (Spatial) Strategies will cause a disjuncture in local development which could impact on economic development. The gap needs to be filled as a matter of urgency.

10.2  Steps also need to be taken to ensure that an overly competitive approach to regional development is not the outcome of the reform process.

10.3  One safeguard which would help would be to make ITAs statutory consultees in local development control.

September 2010

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