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.
1. EXECUTIVE
SUMMARY
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 ABOUT MERSEYTRAVEL
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. REGIONAL
TRANSPORT STRATEGY
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. REGIONAL POLICIES
ON TRANSPORT
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. IMPLICATIONS
OF THE
ABOLITION OF
REGIONAL HOUSE
BUILDING TARGETS
FOR LEVELS
OF HOUSING
DEVELOPMENT
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. INCENTIVISING
LOCAL COMMUNITIES
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. ARRANGEMENTS
TO BE
PUT IN
PLACE TO
ENSURE APPROPRIATE
COOPERATION BETWEEN
LOCAL PLANNING
AUTHORITIES ON
MATTERS FORMERLY
COVERED BY
REGIONAL SPATIAL
STRATEGIES
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. WHETHER LEPS
CAN FULFIL
A PLANNING
FUNCTION
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. ADEQUACY OF
PROPOSALS AALREADY
PUT FORWARD
BY GOVERNMENT,
INCLUDING A
PROPOSED DUTY
TO CO
-OPERATE
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. CONCLUDING
COMMENTS
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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