Written evidence submitted by Cumbria
County Council
SUMMARY
— Cumbria
County Council welcomes Government recognition that regeneration
can be at the heart of driving economic growth and supporting
communities. The Council also broadly supports the approach taken
by the Government in Regeneration to enable growth.
— The
overall ethos of involving communities in their own regeneration
is in tune with the way in which the County Council has long tried
to work with its local residents and communities. It is an approach
that works but for many communities requires long term and committed
ongoing support by local authorities and other public bodies.
— However,
the County Council has some reservations about the viability of
some of the measures outlined in the document, particularly where
they will entail significant capacity-building on behalf of local
authorities or infrastructure organisations.
— The
Council also has some specific concerns about the likely effectiveness
of some of the initiatives such as the Community Infrastructure
Levy, and whether they will be able to stimulate regeneration
in areas of market failure, which exist in parts of Cumbria.
Question—How effective is the Government's
approach to regeneration likely to be? What benefits is the new
approach likely to bring?
General Overview
To answer the second part of the question first,
it would seem intuitively that if communities and neighbourhoods
are more involved in the articulation of their needs and the planning
of solutions to those needs, that those solutions would be more
effective, and that the community would have a greater stake in
its success. However, there are two areas of reservation to this
approach, firstly, that of context, and secondly, that of expertise.
There are also some specific concerns over some of the initiatives
within the document.
Cumbria County Council is pleased that the Eden Valley
has been selected to be one of the Big Society vanguard areas,
and this will prove illustrative as it is the only vanguard area
that is not led by the local authority but by the community itself.
Many of the activities being undertaken by groups in Eden have
been in development for a number of years, and represent local
solutions to identified needs. Eden is fortunate in that it has
a demographic profile with the skills and time required to develop
plans for initiatives such as a community pub. In other parts
of Cumbria, local authority officers are active in working with
less engaged communities to identify issues and solutions. This
public sector resource and funding support is essential and must
be maintained if communities are expected to successfully deliver
local solutions.
Context
In terms of context, many of the measures described
in the document are to be supported, but may not be useful to
citizens when taken out of context. For example, the policy of
transparency means that local authorities must publish full data
on expenditure, to "ensure people can have a clear view of
what is being spent and where". It is questionable whether
this information will actually serve any purpose when taken in
isolation—eg it may be difficult for a citizen to estimate
whether a council's expenditure on, say, social care is inadequate
or excessive.
Whilst the proposed reduction in bureaucracy and
simplification of the planning system is to be welcomed, there
is nonetheless concern that there might be some adverse and unintended
consequences. It is recognised by the planning profession generally
that the LDF system put in place post 2004 has been extremely
time consuming, resource intensive, and over-complex compared
to the old style Local Plan process. Yet, it is most important
that a statutory plan-led system is retained in order to deliver
much needed new development, and that it remains transparent and
accountable. The plan-led system has historically given surety
to the development industry (including the banking system), to
local communities, and to Local Authorities.
Any moves towards planning by appeal, as seen pre-1991,
could lead to far greater uncertainty and unsustainable planning
outcomes, which may ultimately delay new development coming forward.
Reassurances from Ministers still seem to indicate the primacy
of the Local Plan, although the 'presumption in favour of sustainable
development' as referred to in the Localism Bill, would seem to
contradict the plan-led system.
Expertise
It would seem that the solution to this question
of context lies in the Local Enterprise Partnership, as the body
to set local priorities and identify the right spatial level for
interventions. The County Council helped to lead the Cumbria LEP
submission and is committed to making it a success. However, given
that LEP's have no statutory authority, no operational funding,
or guaranteed access to project finance and are still in an embryonic
stage, the future effectiveness of LEPs in driving forward the
desired levels of growth must remain uncertain for the time being.
The document conflates the role of the LEP, the local
authority and the citizen. The result of this is an assumption
that there will be expertise available within the local authority
for the LEP and the citizen to make use of. How else will it be
possible for people to navigate the planning safeguards of the
Localism Bill, set up successful social enterprises, or engage
deprived communities, without the advice and intervention of the
local authority? The onus is then on the local authority to have
officers available for these purposes, which may be challenging
in this public sector funding climate.
Localism Agenda
In terms of local buy-in, the localism agenda, including
the incentives for growth such as the New Homes Bonus and Community
Infrastructure Levy, may assist the delivery of new development
that better meets local aspirations, and reduces protracted local
objection. However, it is now clear the Local Development Framework,
or Local Plan, will still be the principal statutory planning
policy document, and any "Neighbourhood Plan" will need
to be in conformity with it, have been through an independent
inspection, received local referendum support, as well as being
in line with the new National Planning Policy Framework, and be
mindful of planning caselaw. It may be concluded from this that
expectations about what communities can actually do in terms of
"local" planning might be unfairly raised, particularly
as this will still be subject to external factors beyond the control
of the planning system, such as the state of the local market
and national economy; financing; legal constraints; and the willingness
of developers, investors and landowners.
New Homes Bonus
It is possible that the New Homes Bonus will mostly
benefit areas around large metropolitan centres, where growth
can be more easily accommodated, and where land prices and development
values are higher. Since the NHB is based on an average band D
property, it will be of more benefit to the south of the country,
rather than weaker northern housing and commercial markets, and
is more likely to give incentives to Local Authorities to support
larger type housing on greenfield sites, rather than help to address
urban regeneration on difficult, and contaminated brownfield sites.
This criticism has also been made by the Local Government Association
and others in responding to the NHB consultation in late December
2010.
Community Infrastructure Levy
Likewise, the future Community Infrastructure Levy
(as in S106 already) is expected to be less effective in areas
of weak property markets, and where regeneration of brownfield
contaminated sites is a high priority. Other avenues, such as
the use of Local Asset Backed Vehicles or Tax Increment Financing
might be more appropriate in these locations, although again the
development values derived from LA-owned land in failing market
areas may limit the potential of these opportunities. The future
business rate value derived from TIFs may not provide the solution
in risky investment environments.
Inevitably there will be uncertainty over the likely
effectiveness of any new initiatives. It is not clear whether
the areas most in need of regeneration, particularly those areas
of structural and long term decline will benefit from the government's
approach, as defined in this document. It is important that the
new measures are carefully monitored to evaluate their effectiveness.
Question—In particular:
— Will it ensure that the progress made by past regeneration
projects is not lost and can, where appropriate, be built on?
— Will it ensure that sufficient public funds are
made available for future major town and city regeneration projects
as well as for more localised projects?
Agent
The message of the document is very strongly that
it is up to local partners to take charge of their own regeneration.
Again, it is unclear whether the agent of this is ultimately the
LEP, the local authority or the community or individual. Whether
or not these bodies will be able to build on past regeneration
projects is not determined by the document in itself, although
it is useful to have a summary of the support available.
Sources of funding
Sources of proposed public funds for major infrastructure
projects are contained within the "nearly £20 billion
of central government investment", of which £8 billion
can be identified as being for London only. Of what is left, the
only source of discretionary funding is the Regional Growth Fund,
which is specifically for increasing private sector jobs, rather
than longer term area based regeneration programmes. While a vibrant
and expanding business base is necessary for the regeneration
of deprived areas, it will be a challenge for local partners to
ensure that this is aligned with other regeneration outcomes.
There is a real concern that a large number of major regeneration
projects in design or currently partially underway will not be
completed due to the public sector funding gap created by the
demise of the RDAs.
There is also concern for Cumbria around the lack
of focus on rural regeneration. The Community Right to Buy and
the Community Asset Transfer may be helpful in supporting local
communities to save local facilities. However, external factors
relating to financial and legal viability and the state of the
local market may have a bearing on final outcomes in these cases.
As far as other sources of funding, there is no certainty
within the document that particular areas or priorities will secure
any support. Many of the resources for local authorities are undetermined.
For example, the Local Government Resource Review will report
by July, and may "allow authorities to receive direct benefits
for increases in their business rates". The exact level of
income from this, and other schemes such as the Community Infrastructure
Levy, Tax Increment Financing and New Homes Bonus, is as yet unclear.
It is accepted that the continuation of the Homes and Communities
Agency is likely to aid a more cohesive approach in the delivery
of affordable housing and regeneration and this is welcomed.
VCS/Social Enterprises
Coupled with this, funding for VCS organisations
is primarily derived from financial products such as Community
Shares, Social Impact Bonds and Big Society Bank. These initiatives
either imply that the organisation is doing something from which
it can derive an income, or that it is delivering a service that
will have measurable future benefits to society. This is not a
foregone conclusion for many third sector organisations, particularly
in the arts and culture. Their contribution to community and individual
wellbeing is undeniable, but whether this can be measured in a
form equivalent to future savings to public expenditure is open
to question.
Despite this, social enterprises in Cumbria are interested
and positive about the scope offered by Social Impact Bonds in
particular, and it promises some real innovation in delivery.
The concern of the social enterprise, and voluntary and community,
sectors in Cumbria is over the lack of funding for infrastructure
organisations. These organisations offer a much-needed service
to enable capacity-building, and help with the process of bidding
for contracts and putting together business plans. Support for
the continuation of these infrastructure organisations is vital
to enable charities and social enterprises to bridge the gap between
the end of grant funding, and the new financial funding methods
becoming a viable option. It may well be that a number of organisations
do not have the resources to survive this transitional period,
which will have a negative impact on vulnerable individuals and
communities.
Question—What lessons should be learnt from
past and existing regeneration projects to apply to the Government's
new approach?
From a planning point of view, it is recommended
that the Government retain the plan-led system, but reduce the
complexity of it so that plans can be put in place in shorter
timescales, whilst recognising the need for strong evidence bases
to support the policies.
More generally, some useful principles may include:
— Clarifying
the governance structure: as described above, Regeneration to
enable growth lacks clarity around the roles of the local authority,
LEP and citizen. This situation is not helped by the lack of clear
guidance for the legal status and statutory obligations of the
LEP. Although Ministers have given assurances about their willingness
to transfer power to the LEPs, local political difficulties would
be easier to resolve with statutory reinforcement.
— Where
regeneration projects have been effective in Cumbria, project
managers have worked closely with a local community to develop
and refine the specific measures that will have the most impact
on that neighbourhood, and their quality of life. This would reinforce
the ethos of Regeneration to enable growth, but of course has
entailed the time and dedication of a range of agencies, which
is not determined by the document. For example, in Maryport in
West Cumbria, the County Council has worked with local funding
partners to make a number of improvements designed to increase
inward investment, and boost business and tourism in the town.
These include the development of a Business Centre, the creation
of a coastal park from an old coal wash site, and the development
of a master plan for the Harbour. The clear lesson here is that
to be effective regeneration must be holistic in its approach
and coverage. It must also be long term, as there are no short
term fixes for disadvantaged areas faced with structural decline.
— Whilst
challenge funds can drive up value for money and help maintain
quality, competitive bidding can be time consuming and wasteful
of resources.
— New
funding initiatives should be kept as simple as possible, minimising
bureaucracy, red tape and delays. Compliance should be proportionate
to levels of funding received and Government must be prepared
to accept certain levels of risk if communities are expected to
be fully engaged and maintain their long term involvement.
Question—What action should the Government
be taking to attract money from (a) public and (b) private sources
into regeneration schemes?
(a) The Government's approach to partnership
working is innovative, and it is hoped that it will produce significant
gains in terms of maximising the effectiveness of available funding,
and ensuring local partners are well-coordinated in their priorities
and actions. The Government appears to be committed to encouraging
local partners to work more closely together, and the outcome
of pilots such as in worklessness co-design and community budgets
is keenly anticipated, to see how this operates in practice.
These initiatives represent the use of existing,
limited, resources. The impact of the withdrawal of Regional Development
Agency funding in an area such as Cumbria is acute, and has a
direct impact on schemes that have started delivery on the ground,
but which may not be completed. The only other source of additional
funding is from Europe. The Government must ensure that its commitment
within the document to 'encourage alignment, where possible, with
£1.4bn of European Regional Development Funds that remain
to be committed under the current programme' is followed through.
The indication that European Social Funding will be targeted at
those not supported by the Work Programme is to be welcomed.
Other possibilities are to identify local initiatives,
such as assessing the County Council's assets, and using them
through LABVs to generate development potential.
(b) Private sector involvement is a key thread
of much current government policy. The private sector is under
pressure to create jobs, invest in skills and play a role in influencing
strategic development through the Local Enterprise Partnerships.
The reward for business is the opportunity to shape local communities
where there will be higher skilled, healthier employees, who will
drive future productivity. The Government has a role to play in
communicating the importance of this opportunity to business,
which may encourage them to make a greater contribution to regeneration
schemes.
The example of the Nuclear Decommissioning Authority
and Nuclear Management Partners in West Cumbria may be a useful
one for Government to use to illustrate the potential of this
role to other private sector organisations. The NDA and NMP have
played a key role in developing and contributing towards the regeneration
of West Cumbria, in partnership with the local authorities, and
are committed to tackling issues of worklessness and low skills,
among others, in that area.
In contrast, Cumbria has a high proportion of small
businesses, who may struggle to contribute financial or other
resources to regeneration schemes. 85% of businesses in the county
employ 10 or fewer employees, and just 2.6% of workplaces have
more than 50 employees (source: Cumbria Economic Assessment 2010).
These small organisations are already experiencing a challenging
economic climate—in the 2010 Cumbria Business Survey, the
percentage of small businesses with a higher profit margin on
the previous year was 22%.It is unrealistic to expect any significant
levels of SME funding into regeneration when margins are tight
and many businesses are struggling to recover from the recession.
Regeneration to enable growth mentions several financial
products, which should serve to unlock private sources of finance
for public gain, such as Community Shares and Social Impact Bonds.
As above, the implication of these products is that the organisation
can produce a return on that investment, which may be in terms
of future savings to society. In the case of some third sector
organisations or social enterprises, this return is often difficult
to measure, particularly in the arts and cultural sector.
One solution may also be for the Government to encourage
financial institutions to make greater investments in local communities,
and expand their Corporate Social Responsibility programmes so
that they are more co-ordinated with local priorities established
through the Local Enterprise Partnerships. For example, the Northern
Rock Foundation has historically provided a high level of funding
for organisations working in deprived communities in Cumbria.
Question—How should the success of the Government's
approach be assessed in future?
The County Council has welcomed the Government's
commitment to dismantling over-bureaucratic systems of measuring
performance, in particular the system of Comprehensive Area Assessment
and Local Area Agreement, as well as the National Indicator set.
Assessments of future success can be partially determined locally
determined, making use of locally identified measures. Of course,
the danger with all measures becoming locally determined is that
it becomes impossible to define progress in a sub-national or
national context.
However, there are some measurements that could be
used as comparators, for example, the number of developments,
the number of Neighbourhood Plans, and the length of time taken
to approve Neighbourhood Plans and resulting development. This
would give a useful indication about the effectiveness of measures
designed to reduce bureaucracy.
The recent research report Who is ready for the Big
Society (Sutcliffe, R & Holt, R, Consulting Inplace, February
2011) provides a useful basis for measuring change, taking its
source from NI6 —proportion of the adult population participating
in regular, formal volunteering; NI3 —proportion of the
adult population who say they have been involved in decisions
that affect their local area in the past 12 months; NI4 —proportion
of the adult population who agree they are able to influence decisions
in their local area; and from the Place Survey, proportion of
respondents who say they would like to be more involved in the
decisions that affect their local area. Clearly, the National
Indicators won't be available, but if local partners are able
to find a suitable proxy, or a measure from the Single Data List,
this would provide a means of tracking the effectiveness of Regeneration
to enable growth. Some of the National Indicators for housing
(NI154 and NI155) have been particularly useful.
Other ways of evaluating the success of the Government's
new approach is to measure progress against the Coalition's key
objectives of private sector growth and rebalancing the economy
e.g. private sector jobs created, private sector investment, export
led manufacturing.
The proposal announced elsewhere to measure success
through including additional softer, social criteria, as well
as the traditional economic criteria like GVA is welcomed. The
proposal to construct a "well being " or "happiness"
measure which will be included in the Treasury's Green Book appraisal
should give greater weight to social outputs which in the past
have been given less emphasis in cost /benefit analyses.
March 2011
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