Archived decisions
CABINET Item 5
23 June 2008
DISCUSSION PAPER
AND PROPOSED RESPONSE TO THE GOVERNEMENT CONSULTATION ON:
IMPLEMENTING THE SUB NATIONAL REVIEW
1. |
Executive Summary |
1.1 1.2 |
This report deals with the County Council response to the Government's consultation on taking forward the review of Sub-National Economic Development and Regeneration. It is made up of three parts: · A discussion paper (Appendix 1) which sets out the proposals included in the consultation and assesses the implications for: - democratic accountability in the development of an integrated regional plan - the roles of RDAs and Local Authorities - the proposed new economic assessment duty · Draft initial response for the Leader of Hampshire County Council (Appendix 2) · Draft responses to the questions posed in the consultation document (Appendix 3) |
RECOMMENDATION: Cabinet is recommended to 1. consider the provisional letter sent to the Department of Communities and Local Government by the Leader of the Council (Appendix 2), and to approve a final response and 2. to discuss and agree the suggested answers to the consultation questions (Appendix 3) |
DISCUSSION PAPER: APPENDIX 1
"Prosperous Places:- Taking forward the Review of Sub National Economic Development and Regeneration" (31/03/2008)
Page no.
2. Overview of the proposals 55
2.1 Integrated Regional Strategies 55
2.3 The role of Local Authorities (LAs) 77
3.1 Governance and the role of LAs in the Regional Strategy 99
3.2 Organisation and Structure 1010
3.3 A single regional strategy and relationship to LDFs etc. 1111
3.4 Economic prosperity in Hampshire and the proposed new duty 1212
Appendix 2 - recommended draft initial response letter from the Leader 15
Appendix 3 - recommended responses to the consultation questions 19
1. Introduction
On the 31st of March, the Government published its consultation:-
"Prosperous Places. Taking Forward the Review of the Sub-National Economic Development and Regeneration"
The Consultation is based on a review originally published by HM Treasury on 17th July 2007. This review focused on giving local authorities more powers to support prosperity and work effectively with businesses. The key influence for social and environmental well-being was seen to be economic prosperity across all regions of the UK, and the key agencies were seen to be the Local Authorities.
The present consultation (closing date 20th June) has been published jointly by two Government Departments: DCLG and DBERR.
They are seeking, in summary, views on proposals for:-
· a new, integrated regional strategy
· the replacement of voluntary Regional Assemblies with a locally determined "Leaders" Forum for elected Local Authority Leaders.
· the introduction of a new statutory economic duty for upper tier and Unitary Local Authorities.
The discussion paper, which follows, sets out the proposals in the consultation, presents some of the issues and recommends answers to the questions posed by the Government.
Cabinet is asked to consider its views for recommendation to the Leader, who will be writing a holding reply to DBERR, pending formal adoption of the County Council's response at the Cabinet meeting on the 23rd June. A draft `holding reply' is attached as Appendix 1.
2. Overview of the proposals
2.1 Integrated Regional Strategies
2.1.1 Under the Sub National Review (SNR) proposals, a single `Integrated Regional Strategy' would replace the currently separate regional spatial strategy (RSS) and Regional Economic Strategy (RES). Regional Assemblies would be abolished, with the Regional Development Agencies (RDAs) becoming responsible for the integrated regional strategy including economy, transport and housing, as well as regional funding allocations.
2.1.2 The RDAs would continue to be `business-led', but the consultation document proposes that local authorities should work with their RDA to develop and implement the regional strategy. A local authority `Leaders' Forum' would take strategic decisions and agree priorities on behalf of all local authorities in the region, including signing-off the regional strategy. The Government expects local authorities to agree the draft strategy for submission to Ministers, the document says, but adds that if such agreement is not forthcoming, the draft strategy should be submitted anyway, accompanied by a note of the points of disagreement.
2.1.3 Local authorities in each region would be able to decide the structure of their `Leaders Forum' subject to its being streamlined, manageable and able to make strategic long-term decisions, its being representative of key sub-regions and upper and lower tier authorities, and its being composed of Leaders with sufficient authority to sign-off the draft strategy on behalf of all the local authorities (the inference being that the Forum would not include every local authority in the region.). The Government would only intervene in the formation of the Forum, if the local authorities were unable to reach a consensus.
2.1.4 The consultation document intends that the new-style strategies should "ensure closer alignment between economic and spatial planning to support sustainable economic growth". This is reinforced in the statement of the Government's `priority outcomes', of which there are just two:
· improved regional economic performance and
· increased housing supply and affordability.
The regional strategy would cover the overall economic strategy for the Region and also include house building targets for individual borough/district councils, unless groups of local authorities commit to preparing joint local planning documents, which would apportion the overall total for their area set out in the regional strategy.
2.1.5 Government would provide firmer policy guidance at the outset of strategy preparation, including a regional economic growth objective and a target house building range. The Consultation Document expects that this, coupled with improved project management, should enable a full regional strategy review to be completed within 24 months.
2.1.6 Regional Assemblies and RDAs are expected to begin work in advance of legislation, and some regions (according to the document) are aiming for integration as early as 2010.
RDAs would take on the duties of the current Regional Assemblies alongside those of supporting economic prosperity. They would also be required to delegate their budgets to Local Authorities, or groupings of these, or to Business Link where their activities related to business support (under the Business Support Simplification Programme - `BSSP').
Effectively, they would become strategic bodies engaged in the development of region-wide policy not delivery. The document does not however, provide any indication of the level of funding which would be delegated (eg transport programmes).
However, RDAs `will continue to manage and deliver those services which are best implemented at the regional level'. Those services include: business support, co-ordinating inward investment, support for innovation, and `responding to economic shocks'.
2.3 The role of Local Authorities (LAs)
2.3.1 At the strategic and regional level, LAs and their `Leaders' Fora' are expected to fulfil a number of roles:
· They are expected to `work with the RDA to develop and agree the draft strategy and its delivery'.
· They are expected to achieve `co-ownership of the vision for each region and its delivery'.
· They are expected also to have a `role in holding to account the RDA and its regional delivery partners'.
This is a complex and potentially conflicting set of roles.
2.3.2 In addition, the SNR gives strong support for the `place-shaping' role of Local Authorities, following the guidance from the earlier `Lyons Report'. This is seen to flow from their role in sustaining and developing their local economies by the application of both statutory and discretionary funding.
Comprehensive Area Assessment: Para 5.1 of the document refers to the holistic approach adopted by Government in developing the new performance framework (the set of 198 National Indicators and the prioritisation through the Local Area Agreement process). It also refers to the concordat between central and local government for it to `provide effective leadership of the local area and to empower local communities.'
Skills: There are references to the role of LAs in developing skills and their important involvement in working with `other partners to develop an agreed view on the skills and training priorities that will best support delivery of regional and local economic development'. LAs are also seen to be key drivers behind the setting up of sub-regional `Employment and Skills Boards', following the recommendations of the Leitch Report. The transfer of the 14-19 Agenda will reinforce the critical integrative role of LAs in driving their local economies and responses to the skills needs of business.
However, the document is less than precise on adult skills development (para 3.33). It states: "we therefore look to the LSC, RDAs, local authorities and other partners to develop an agreed view on the skills and training priorities that will best support delivery of regional and local economic development, within the overall framework of the national skills strategy and PSA targets. Where appropriate, that should include considering how different funding streams can be aligned to ensure skills priorities best complement wider economic goals".
Transport: Planning for this will be both at the regional and sub-regional level. Regional Funding Allocations (RFA) will take account of the need to align and prioritise within the economic, transport and housing needs of the region. Through the Regional Funding Board, allocations may be made to Transport Authorities, sub regions, or groups (eg Transport for South Hampshire).
Economic Development: Local Authorities are seen as having a clear leadership role for their local economies. They should `work with partners to deliver parts of the strategy at sub-regional and local level'. In order to encourage the prioritisation of this part of their role, Local Authorities are to be given a new statutory duty. The first assessments would be undertaken to inform local strategies and local area agreements for 2010/11.
Costs of the new duty will be met by Government.
2.4 The proposed new duty for economic development
2.4.1 The Government propose to legislate for a new statutory duty for economic development. Whilst there is, at present, a general power under the Local Government Act 2000 to `promote the economic, social and environmental well-being' of an area, it is entirely optional for a Local Authority to engage in economic development. This is seen as undervaluing the importance of this activity, which effectively underpins the general well- being of the whole community.
2.4.2 HM Treasury and DCLG did consider imposing an overriding economic duty on all Councils, but were advised by their lawyers that such a requirement would have to be fully funded (under the `lifting the burdens' principles) and would effectively imply an open-ended funding commitment for the Government. Instead, they have opted for an economic assessment duty, under which upper tier Local Authorities and Unitaries would undertake a wide-ranging analysis of their local economies. District Councils `should be fully involved' (para 5.19) and in practice it is improbable that such an assessment could be undertaken without close involvement of the lower tier especially in view of their Local Development Framework responsibilities.
2.4.3 The Consultation proposes 3 Options -
· Detailed guidance (Option 1)
· Outline guidance (Option 2)
· No statutory duty (Option 3)
In Options 1 and 2, there would be a requirement for other agencies to be involved, though the document is rather vague on this.
2.4.4 The assessment may be `produced jointly by two or more lead authorities in a single functional economic area or sub-region, for example by all authorities participating in an MAA'.
2.4.5 The Audit Commission inspectors would take account of the effectiveness of local economic assessments as part of the evidence base of the new Comprehensive Assessment (CAA)
2.5 `Cross-border arrangements' (LAA/MAA)
2.5.1 The existence of sub regional partnerships across the country, which recognise economic areas transcending local authority borders, is a key theme of the document (see 5.27 and following paras). MAAs are seen as one of the main levers towards this aspiration.
2.5.2 It is also suggested that MAA areas could eventually become `statutory sub-regions' with appropriate powers to steer the economic fortunes of their area, if the local area so wished.
2.5.3 The document refers to the complementary proposals in the Local Transport Bill which enables cross border transport authorities to be established outside metropolitan areas (Integrated Transport Authorities). Transport is seen as critical to economic performance and the document notes Government is considering whether to delegate, to the regional, sub-regional and local authority level, some planning decisions on transport projects currently made by the Secretary of State.
3. Issues arising:
3.1 Governance and the role of LAs in the Regional Strategy
3.1.1 Each region would have the flexibility to decide on the composition of its `Leaders' Forum'. This would enable each Forum to reflect the circumstances of the region and the preferences of its constituent local authorities. Having said that, the proposals assume that the Leaders' Forum will be willing and able to make decisions on behalf of all local authorities in the region, notably signing-off the draft regional strategy. Whether this is realistic is questionable, both because of the short timeframe which the consultation document envisages for the leaders' signing-off the draft strategy (This will be insufficient for all local authorities to individually consider it before the leaders' decision) and because in a large region such as the South East, the Leaders Forum may not be able to include every authority if it is also to meet the Government's criterion of being "streamlined and manageable".
3.1.2 There must also be concerns about the democratic deficit which would result from the proposals. Few may mourn the demise of the regional assemblies, but arguably the proposed successor arrangements are even less palatable. The transfer of strategic and regional planning to regional assemblies in 2004 reduced the influence of democratically elected local authorities. The SNR proposals would reduce that influence even further, by moving responsibility for regional planning to a body comprising largely of non-elected appointees, relegating local authorities to little more than major consultees. The County Council is proposing to remedy that with the suggestion that 50% of RDA Boards should be made up of elected Councillors.
3.1.3 Social and environmental partners currently have seats on regional assemblies and their regional planning committees, giving them a direct involvement in RSS preparation. The consultation document proposes to leave individual RDAs to decide how to involve these bodies. The County Council will undoubtedly wish to support at least some obligation to consult with social and environmental partners as part of the process to develop the new Integrated Regional Strategy, though it would not see them forming a part of the governance arrangements themselves.
3.2 Organisation and Structure
3.2.1 RDAs and their relationship with LAs:
This has been an area of some tension on occasions though many Local Authorities work closely with their RDAs in developing economic programmes. Indeed the County Council itself delivers a number of initiatives under contract from SEEDA e.g. the Market Towns Programme , and the Chief Executive of SEEDA has agreed to join the new Hampshire Senate.
The critical issue is the perceived democratic deficit in RDAs, which is unlikely to be remedied by the setting up of a parallel `Leaders' Forum'. The extension of RDA responsibilities to include spatial and transport planning (as well as a significant role in skills) makes it all the more important that there is reform to the accountability of RDAs. The most effective solution would be to make them directly answerable to the Leaders' Forum. If the Government persist with the view that the RDAs should continue to be business-led, then there will need to be clear guidance as to the powers of the Leaders' Forum to direct and scrutinise.
Many Local Authorities have developed good working relationships with their RDA. However, if the SNR is to deliver on its aspirations to pass the `place-shaping role' to the LAs there will have to be a substantial reduction in the bureaucracy of regional level initiatives and a significant delegation of budgets and programmes to the LAs. It remains to be seen how this will work in practice since RDAs are treating many of their programmes as Business Support and contracting with their Business Links under the BSSP.
In the south east, the principle of delegation is based on Local Area Agreements , and the `Diamonds for Growth' (in Hampshire: Basingstoke and south Hampshire). However, there are questions over the mechanics of this, and over relationships with rural areas. It is not clear for example what process is involved in the delegation of funding - whether it is on a case by case basis or a complete programme. If the principles of the SNR are to work in practice, there will need to be significant progress made in the delegation principles and processes.
The Review also questions how RDAs can assess the capacity of LAs to take on RDA work. Given that upper tier Authorities and Unitaries run multi million pound budgets , this seems an odd question. However, the solution seems to best provided in the form of a section of the CAA which could report on LA capacity in respect of economic development. Clearly a 4 star Authority like Hampshire is unlikely to have problems delivering delegated regional budgets.
3.3 A single regional strategy and relationship to LDFs etc.
3.3.1 A single Regional Strategy is a laudable aim. Incorporating the elements that are currently contained in the Regional Spatial Strategy (South East Plan), and the Regional Economic Strategy should provide for a greater correlation of spatial planning with sustainable economic development. This may result in local planning authorities being made more aware of the importance being placed by central government on economic development - as evidenced in Draft Planning Policy Statement 4.
3.3.2 The proposal for a single regional strategy is a laudable one in principle, as it would resolve the current confusion in many peoples' minds over the respective roles of the RSS and RES. However, there are many practical difficulties. At present, the two documents have a different status - one is statutory, and the other is `adopted' by Ministers. They are also the result of very different preparation processes. The RES is produced over a relatively short period of time, with consultation essentially limited to key stakeholders and their representatives; the RSS preparation involves several rounds of public consultation and a public inquiry, where stakeholders including Local Authorities can articulate their concerns before an independent panel of planning inspectors. The Consultation document is largely silent on the practical issues of how to merge the two quite different strategies and preparation processes.
3.3.3 A list of what the integrated strategy should contain is given at para 4.13 of the consultation, and references are made to targets for economic growth - `to raise the sustainable trend rate of growth in comparison with the previous economic cycle' - and housing provision (paras 4.8/4.9)'. The economy and its success is placed at the centre of policy development. However, whilst it is true that economic prosperity in general underpins social and environmental quality of life, it should not be to the exclusion of additional criteria relating to sustainability.
3.3.4 The Government does recognise other criteria, in its desired outcomes, beyond economic growth and housing provision as set out in para 4.5 of the consultation, but no targets are proposed. The Government should therefore also set out its proposals for its own target-setting on other aspirations of the strategy, e.g. climate change, in order to give focus for the expression of these requirements. It is also important that the proposals for changes to the planning system (Draft PPS4 - Planning for Sustainable Economic Development) align fully with this approach.
3.3.5 Target setting - the Council does not in general support the practice of centrally set targets since it is for the local area to determine what is and is not possible and to negotiate agreements with Government in the context of the national goals.
3.4 Economic prosperity in Hampshire and the proposed new duty
The proposals to pass more power and control over HMG resources for economic development from RDAs to Local Authorities should be generally welcomed along with the establishment of an economic assessment duty.
There are however some specific issues:
· There needs to be a requirement for RDAs to passport a significant proportion of their budgets to the sub regional level to implement the range of support and interventions, which would be set out in the Regional Plan.
· Local Authority `Leaders' Fora' should also have the power to scrutinise RDA implementation budgets, and to intervene to reduce regional level spend and ensure appropriate levels of support.
· In relation to the options for the proposed duty, Option 2 appears to be the best, but enhanced with a requirement for named partners to supply data and co-operate. These partners would include Job Centre Plus, Learning & Skills Council etc.
· Detailed or statutory guidance on the format of the assessment would not be appropriate, but general outline guidance on the elements to include (eg skills/labour market; enterprise; land development; transport; deprivation etc.) could be helpful in engaging partners. This would also contribute to a degree of comparability across areas which, along with the involvement of Districts through the local partnerships would be important. The effectiveness of collaboration should be subject to assessment through the CAA (which should include references to the economic partnership approach). Lead Authorities should be the upper tier with a requirement to consult with Districts and gain partner sign off.
· Guidance should also include a statutory requirement of other Government agencies (including RDAs) to demonstrate how they are responding to the assessment.
The proposal to support the costs of undertaking the assessment with supplementary funding is welcomed but there is no need for HMG to impose statutory sub-regional partnership arrangements at the local level as powers, if needed, are already available to set up Joint Committees, Development Companies etc..
3.5 HCC and its partnership arrangements
3.5.1 Sub-regions:
The SNR puts significant emphasis on economic sub-regions, giving much weight to MAAs and the potential for them to become significant influences on economic prosperity. The SNR also holds out the possibility of establishing `statutory sub-regions'. In the case of Hampshire, the most obvious candidate would be the Partnership for South Hampshire (PUSH) of which the County Council is a member along with 10 other Local Authorities. However, whilst such a partnership quite properly recognises the existence of economic linkages in the south Hampshire area, it would not be appropriate to establish governance arrangements on that basis for all areas of work in which the County Council is involved. Indeed, the County Council, along with its partners has set up a Joint Committee with a focused brief and terms of reference to address the specifics of services where joint working can add value to the local economy. It would be hard to see what added value the designation of south Hampshire as a `statutory sub- region' would bring.
The document also seems to relate much better to large urban conurbations and is weak on `cross-regional working' (e.g. east Dorset has clear economic linkages with south Hampshire). No reference is made to rural areas which often cross through sub-regions. The County Council's forthcoming Rural Strategy will cover all rural areas of the county including those in south Hampshire. Guidance on the economic assessment should recognise that there are different needs between rural and urban areas.
In essence, the County Council view is that the region of Hampshire, for which it is responsible, is of significant scale to make for effective delivery as a `sub-region' in its own right. Rather than scaling down the County into subdivisions, the Council is looking to expand its linkages with surrounding areas to work across county boundaries (e.g. with Thames Valley in the north). There is a danger that sub-regional designations such as "Diamonds for Growth" in the South East could lead to a concentration of resources at the expense of other areas in need.
3.5.2 Transport partnerships:
Hampshire County , Southampton City and Portsmouth City Councils established a joint committee with delegated powers (Transport for South Hampshire) last year, in parallel with the PUSH joint committee, building on the previous informal transport partnership arrangements. It is helpful that such arrangements are being recognised by Government. The enabling powers being proposed in the Transport Bill which would allow a further transition to a formal cross-border transport authority may be of future interest, although in general the County Council favours devolution of powers and funding directly to the Local Authority level, with them deciding where to pool these.
4. Conclusions
In summary, the Council welcomes some of the principles set out in the SNR such as the Leadership and `place-shaping' role of Local Authorities, the integration of the regional strategies, and the introduction of a statutory economic assessment duty.
However, it has grave concerns about some of the governance structures proposed, particularly those relating to the relationship between RDAs and the proposed Leaders' Forum. The Council considers that RDAs do not have sufficient sub national responsibility and tend to operate as an unelected executive arm of Government. Our view is that they should continue to be separately constituted with their own Boards. Boards though will need to be more balanced with stakeholder interests beyond the business community, if they are to take the lead in producing a Regional Strategy capable of balancing the often competing interest of economic growth and environmental and social concerns. In addition, RDAs should be made subordinate to the Leaders' Forum in terms of decision-making powers.
The Council welcomes the proposals to delegate substantial proportions of RDA funds to Local Authorities and groups of LAs, but wishes to see clear passporting of funding possibly supported by a Memorandum of Understanding as referred to in the document.
APPENDIX 2
Draft letter from the Leader in response to the SNR Consultation
Date: 14th May 2008
Dear Sirs,
Re: Consultation Paper - Prosperous Places: Taking Forward the Review of the Sub-National Economic Development and Regeneration
My Council has informally considered the proposals put forward in the above consultation and this letter is our preliminary response. Our Cabinet meeting on the 23rd June will agree our formal position and we will be submitting our final response at that time. We would appreciate your flexibility in allowing us to exceed the deadline by a few days.
In general, my Council welcomes the debate which this consultation has engendered. We are strongly committed to developing our local economy in a sustainable way and strongly believe that Local Authorities, especially those with sufficient critical mass, are well-suited to lead the place-shaping agenda.
We also, however, have a number of concerns:-
1. Integrated Regional Strategies:- it undoubtedly makes sense for there to be an improved correlation of economic investment, infrastructure and development policies. Detailed consideration, however, needs to be given to the spatial levels of the Plan - the South East region is very large and diverse - and the processes by which the Plan is developed are complex. Mechanisms will have to be found of broadening the outcomes and performance framework for the Plan, in order to reflect social and environmental priorities as well as those for the economy.
The Council is also highly sceptical of the timescales envisaged for the production of the Plan and would need to hear more detail as to the processes of consultation and production involved. Given the expertise available to this Council we would expect a substantial and very real contribution to the development of the Plan. It is not clear in the document that individual Local Authorities will be treated as anything more than consultees.
2. Accountability and governance: - along with many other Councils, we deplore the growing power being allocated to Regional Agencies. Whilst they undoubtedly bring technical experience to their work, they have no accountability to the people of the region.
The County Council's position, shared with that of the South East County Leaders, is: -
· The Leaders' Forum proposed in the SNR should be the `accountable body' for the region
· The RDAs should effectively report to the Leaders' Forum, providing it with expert advice, and proposing technical reports. It should become the executive arm of the Forum
· RDA Boards should have 50% of their membership made up of elected representatives from the Local Authorities. It is unlikely that County Council Leaders will feel able to co-operate with the process if this requirement is not met
· Programme and project budgets of the RDAs should be delegated or, better still devolved, to the upper tier and unitary Local Authorities in the region, (or sub-regional groupings as appropriate) for them to implement, with their partners, the delivery of the Regional Plan. Accountability should be through the Local Area Agreements not through the regional tier
3. Local Authority capacity: - the SNR poses the question as to how an RDA should assess the capacity of a Local Authority to manage delegated budgets. As the Leader of a four star Council, managing budgets in excess of £2 billion, I find this question surprising given the significant role played by strategic authorities in contributing to and driving the development of the work of the Regional Assemblies. Public money currently being administered by the RDAs should be passed direct to the upper tier and unitary authorities, to support their economic strategies. A minimum percentage (which grows annually) should be set for this transfer. In the model, which I am proposing, there would be a regional Leaders' Forum, to which the RDA would be responsible, and the Local Authority partners would deliver programmes indicated by the regional plan at the strategic authority level.
This, in my view, is the way to achieve a more effective integration of many of the mainstream statutory services provided by the Local Authorities e.g.: -
· Skills and education
· Economic Development including urban and rural regeneration
· Transport
· Development Plans
· Community and cultural development
· Productive management of property assets etc.
4. Local Authority economic development - the proposed new duty:-
My Council supports the proposal to introduce a statutory economic assessment duty. However, we believe the emphasis should be as follows:-
· Light touch guidance from government limited to the level required to achieve some comparability across the country
· Statutory requirement on other government agencies to demonstrate how they are responding to the assessment - in effect, the duty should lead to the production of a framework for public investment.
· Upper tier and unitary authorities to be charged with leading the assessment, but required to work in partnership with other relevant local authorities/ partners.
· Significant emphasis on the Local Authority co-ordinating role in skills strategies. Para 3.33 of the consultation is weak on this aspect. Guidance for the proposed duty, which emphasises this aspect of the economy, would underpin the Local Authority role.
5. Sub-regional Partnerships/ MAAs: - the Consultation makes a number of references to cross-boundary groupings and the possible need to give more formal status to these. However, my Council feels that it is perfectly capable of evaluating and forming cross-boundary partnerships appropriate to the outcomes which it is trying to achieve, without needing additional government legislation. For example, in Hampshire we work closely with other Local Authorities in the Partnership for Urban South Hampshire (PUSH) with its focus on economic growth, but we are also developing rural development partnerships and transport partnerships which relate to or cross other Local Authority boundaries. There is no `one size fits all' solution here!
Hampshire County Council in itself is a large and significant Authority, which delivers services to over 1m people. As a large entity it is able to provide cost effective services and form appropriate groupings to suit particular needs, not just in subdivisions of the County itself but linking up with areas outside Hampshire eg. with parts of the Thames Valley and Surrey. Furthermore, a proliferation of smaller city-region driven sub-regions could seriously exclude and disadvantage rural areas.
Decisions on these matters should be entrusted to locally elected bodies who are held accountable but best placed to make decisions, which reflect a proper balance of interests between economic growth aspirations, environmental sustainability, social welfare and overall quality of life. Only locally elected politicians are truly capable of judging the proper balance of competing interests in their particular area.
In conclusion, I would like to emphasise our response to two aspects of the Review: -
· the importance of locally-elected leadership in shaping the quality of life and place for all our citizens;
· the need to pass power to the lowest appropriate level of government. In most respects, a County the size of Hampshire can provide an effective local partner for central government, without the need for intervention at the regional level.
· Regional interventions should be confined to providing a framework for overall regional targets - delivery should be left to those who work most with the local interests.
I attach, as an Appendix, the Council's response to the questions posed in the Consultation.
Yours etc
HCC Leader
Appendix 3
1. Stronger partnerships for regional growth
Q1. How should RDAs satisfy themselves that sufficient capacity exists for programme management and delivery at local or sub-regional level?
The question might be reversed and asked as `how can large and established Local Authorities satisfy themselves that Regional Development Agencies have the appropriate experience and skills to develop Spatial and Transport Plans?'. Hampshire County Council is a large four star rated Council so capacity would not be an issue. However, if reassurance is needed it should be provided through the Comprehensive Area Assessment (CAA) process. When the Local Authority has a high-performance rating, there should be a presumption that funds should be delegated.
Q2. Do you agree that local authorities should determine how they set up a local authority leaders' forum for their region, and that the Government should only intervene if the required criteria are not met or if it failed to operate effectively? If not, what would you propose instead?
Yes, this approach is supported. It will enable each forum to reflect the circumstances of the region and the preferences of its constituent local authorities. However, we have concerns at the inference that the Forum may not include the leaders of all local authorities ( a worry which is particularly relevant to large regions such as the South East) as this would prevent the direct involvement of every local authority in the strategy preparation process. This concern is heightened by the tight time frame envisaged for strategy review preparation, which will constrain the ability for those leaders who are members of the Forum in turn to consult meaningfully with those who are not. This would be disadvantageous for the process because it might alienate authorities who would otherwise be content if they had a reasonable opportunity to express their concerns. The Forum should involve all leaders with a representative number forming an executive group.
Q3. Are the proposed regional accountability and scrutiny proposals proportionate and workable?
No. Regional Development Agencies should report through their Boards to the Leaders' Forum. Only in this way can sufficient democratic accountability be achieved in evaluating the often competing priorities implicit in the Regional Plan. RDA Boards should have 50% membership from elected representatives of Local Authorities.
2. Integrating regional strategies to promote growth
In general, the County Council welcomes the abolition of regional assemblies, but regrets that the opportunity has not been taken to return the assemblies' strategic planning powers to county and unitary councils. Such a move would have returned strategic planning to the control of directly elected government, would have restored the links with the county/unitary councils' responsibility for major areas of infrastructure provision (transport, education, social care, greenspace). The County Council believes it is fundamentally wrong that public policy should be formulated by a private sector-led organisation.
Q4. Do you agree that the regional strategy needs to cover the elements listed at paragraph 4.13? Are there other matters that should be included in the regional strategy to help in the delivery of key outcomes?
The elements listed in 4.13 do need to be covered by the regional strategy. The environment and quality of life should be added to the list because these are important components of sustainability/sustainable development and also because a high quality environment is an important part of the attractiveness of an area for business investment.
The outcomes themselves (listed in paragraphs 4.6 - 4.11) are too narrow in comprising solely of improved economic performance and increased housing supply and affordability. We accept that economic growth and prosperity are important, but there should also be targets relating to the environment and quality of life.
The Regional Strategy is welcomed, as is the ability for each region to self-determine its priorities to achieve sustainable economic growth and development. Since it is the view of the County Council that transport provision and management along with the integration of spatial planning and transport planning is critical to sustainable economic growth and the delivery of housing growth, the inclusion of transport in paragraph 4.13 is welcomed.
Q5. Do you agree with the way in which we propose to simplify the preparation of the regional strategy, as illustrated in the figure [on page 35], in particular allowing flexibility for regions to determine detailed processes? If not what other steps might we take?
The process seems to be reasonable, except for the omission of any consultation by Government on its proposed changes to the submitted regional strategy. That consultation is a vital part of the current system: it enables a reality check to be made on any changes by the Government and helps build ownership of them. The absence of such consultation would be likely to lead to greater recourse to legal challenge as the only option available to disgruntled parties.
The proposed involvement of an independent panel throughout the process could provide a helpful validation of policy proposals as they emerge, but is unlikely to ensure a proper evaluation in the initial development of planning approaches.
Flexibility for individual regions to tailor the detailed process to the circumstances of their region is supported.
However, the timescale is unrealistically tight, based on the experience of the current round of regional strategy preparation. It could mean insufficient time to enable consideration, and thus `buy-in', by local authorities and other stakeholders of the draft strategy. Two months for the Government to approve the strategy seems highly implausible given that the Government has still not published its proposed changes to the South East Plan nine months on from the EiP Panel submitting their recommendations.
The proposal that the draft strategy will still be submitted to the Government by the RDA even if it is not `signed-off' by the leaders forum is strongly opposed. This would relegate local authorities to the status of mere consultees in the process, and would amount to the imposition on local authorities of a strategy/ policies drawn up by a business-led body. Negotiation and consensus building with local authorities should be the approach, rather than a process of imposition.
In our view, there should be a joint agreement of the draft strategy by the RDA and councils before it is submitted to Government, and the strategies only submitted when agreed. A formal regional process for the resolution of disputes should be set up by the RDA and councils with a "dual key" principle at the heart of the process.
Implementation of the strategy will largely be through local authority plans and actions, notably Local Development Frameworks, so securing their buy-in is essential. Extra time spent securing that buy-in at the strategy sign-off stage, would save time later.
Q6. Do you think that the streamlined process would lead to any significant changes in the costs and benefits to the community and other impacts?
The transfer of powers to develop the integrated Regional Plan to a non-elected body reduces the accountability of proposals and thus the sensitivity to local and community wishes.
In addition, social and environmental partners have seats on the regional assemblies and their regional planning committees, giving them a direct involvement in RSS preparation. The consultation document proposes to leave individual RDAs to decide how to involve these bodies in the emerging new-style regional strategies; the County Council would welcome the inclusion of social and environmental partners as consultees. This would help ensure an inclusive process, which reflects community needs.
3. Strengthening sub-regional economies - the role of local authorities
Q7. Which of the options for the local authority economic assessment duty [or any other proposals] is most appropriate?
The County Council supports a `light touch approach' i.e. Option 2. The government should provide framework guidance sufficient to allow comparison across areas, but not prescribe the contents. There should also be a statutory requirement for government agencies to demonstrate how they propose to respond to the assessment.
Q8. What additional information or support do local authorities consider valuable for the purpose of preparing assessments?
Economic assessments should cover all the critical components of economic success, including those referred to in the SNR, but also covering issues relating to enterprise and innovation, investment trends etc.. The inclusion of skills is a key component which would strengthen the Local Authority co-ordinating role in this key area of the economy.
The assessment should also draw on information from government Departments (e.g. transport) to develop, in effect, a public sector investment framework.
The document also seems to relate much better to large urban conurbations and is weak on `cross-regional working' (e.g. east Dorset has clear economic linkages with south Hampshire). No reference is made to rural areas which often cross through sub-regions. The County Council's forthcoming Rural Strategy will cover all rural areas of the county including those in south Hampshire. Any Government guidance on the economic assessment should recognise that there are different needs between rural and urban areas
Q9. How should lead local authorities engage partners, including district councils, in the preparation of the assessment?
The duty should also require upper tier and unitary councils to involve lower tier and neighbouring councils in the preparation of the assessment.
Q10. Which partner bodies should be consulted in the preparation of the assessment?
Partner bodies will include business-led representative organisations, relevant government agencies and departments and social/ environmental partners.
It should be a statutory requirement on government agencies (such as RDAs, Job Centre Plus and Departments) to demonstrate how they propose to respond to the assessment.
Q11. Should any duty apply in London and, if so, which of the proposed models is most appropriate?
Option 2 as above.
Q12. Do you agree that there is value in creating statutory arrangements for sub-regional collaboration on economic development issues beyond MAAs? What form might any new arrangements take?
The Council considers that that there is no point in creating statutory partnerships as proposed since:
1) MAAs are at a very early stage. It would be better to wait to see whether the first round of MAAS can operate effectively and whether enabling measures requested of Government prove to make a difference. If MAAs in the longer term have been successful there could be a review of the need for further provisions;
2) local authorities can create sub-regional partnerships (e.g. joint committees) under existing powers, without the need for further statutory provisions; and
3) the MAA literature review tells us that voluntary partnerships are better than enforced partnerships
There is also a danger that the development of a further statutory basis for such sub-regional partnerships would stifle the emergence of other non-statutory partnerships.
The Council agrees with the consultation at paragraph 5.43 (page 47) that a reasonable alternative for (non-statutory) sub-regional arrangements is to extend the duty to cooperate for LAA partners to MAA partners. We would caveat, however, that this must be accompanied by enhanced enforcement mechanisms for MAA partnerships to require cooperation and responses from partner agencies.
Q13. What activities would you like a sub-regional partnership to be able to carry out and what are the constraints on them doing this under the current legislation?
They should be focused on economic linkages. It would not be appropriate to establish governance arrangements of this sort for all areas of a Council's work.
As a key player in one of the pilot MAAs (Partnership for Urban South Hampshire- PUSH) our engagement with the MAA process will contribute to a clearer picture on this issue.
In addition, it is felt that the provision and management of transport infrastructure, along with linked measures to promote sustainable transport choices, is critical to facilitating sustainable economic growth and to deliver the housing growth outlined in the current South East Plan. Mindful of the housing and economic growth agendas being pursued, it seems a sensible way forward for sub-regional partnerships to have the ability and opportunity to assume the responsibilities of an integrated transport authority for planning and delivering sub-regional transport. In practice though it will only be effective in so far as power and resources are also devolved.
Q14. How would a sub-regional economic development authority fit into the local authority performance framework?
The Local Authority would be assessed in the CAA on its commitment and the effectiveness of support for its local economy. Partnerships and delivery arrangements would form part of that assessment, including any participation in a sub-regional economic development authority.
The absence of an overall GVA/head in the National Indicator should be remedied to allow more emphasis to be placed on the Local Authority's overall commitment to its local economy.
At present, MAAs are not measured or constrained in the same way that LAAs are. Hampshire County Council's view is that MAAs should be subsidiary to the LAA but also complementary to it: the LAA is about local needs and local solutions for improvement and the MAA is a much more strategic, economic based approach. There will be certain areas within both LAAs and MAAs where inter-relationships are likely. In such instances, it is important that where an LAA has measures that contribute to the MAA, that they are synchronised
Q15. Should there be a duty to co-operate at sub-regional level where a statutory partnership exists? To whom should this apply?
There should be, as suggested, a duty to cooperate in MAAs and for partner agencies to respond to the constituted partnerships of local authorities. No commitment should be made at present to setting up statutory partnerships.
Complementary to this, the Council believes there should be a requirement on publicly-funded bodies (for example, government departments and agencies) to demonstrate how they propose to respond to the Upper Tier and Unitary economic assessments, as proposed at Question 10.
The intent of the Sub National Review is for Local Authorities to take a more powerful role in leading the place-shaping agenda. In order for this to happen, strategic Authorities, such as Hampshire County Council, need to be given increased influence over what Government agencies and Departments deliver in their areas. It is only in this way that there can be effective `on-the-ground' delivery of economic development and regeneration. A duty to co-operate (e.g. on the basis of the economic assessment and Local Area Agreements) would help strengthen this co-ordinating role.