Devolving local major transport schemes response form
Specific questions
Part 1:Local transport bodies – this section of the consultation document set out the context, rationale and objectives for forming local transport bodies. It also consider the options for distributing funding, facilitating strategic investment and the role of Local Enterprise Partnerships in decision-making.
1.Do you have any comments on the proposed role and membership, preferred scale and geographical scope in forming local transport bodies and consortia, in particular the options to facilitate strategic investment decisions and the types of schemes to be funded?
Response:In view of the DfT’s declaration: “It is essential that [local transport] bodies make decisions which genuinely represent what is right for local areas, and therefore they must be democratically accountable to the local electorate” (para. 1.29, p. 10, of the consultation paper – our underlining)the North West Transport Roundtable (NW TAR) fails to understand why the DfT is apparently so enthusiastic for Local Enterprise Partnerships (LEPs) to be a part of them. LEPs are not democratically accountable. Nor are they serviced by teams of neutral, professional officers who are required to operate in a transparent manner, as is the case for local authorities.
If the government wishes to devolve decision-making to locally accountable groups/ individuals, they should stipulate that one or more seats on the transport bodies are awarded to the regional federations of Local Councils which are made up of elected representatives of the CountyAssociations of Town & Parish Councils within each region. It is equally important that social and environmental partners are awarded membership in the form of at least one voluntary sector representative and at least one representative to be nominated by the Campaign for Better Transport *. This would ensure that each body had voices which were making the case for social inclusion and for sustainability.
* N.B. The DfT entrusted the Campaign for Better Transport (CfBT) - formerly Transport 2000 - to nominate the NGO environmental representatives who sat on the multi-modal studies.
*Maximum 400 words
2.Do you have any views on the membership of Local Enterprise Partnerships in local transport bodies, in particular whether they should have the final say in decision-making? Or on any other issues raised in relation to Local Enterprise Partnerships, and potential resourcing impacts?
Response:Local Enterprise Partnerships (LEPs) are a worrying innovation because of the lack of prescription relating to their structures and decision-making processes.
MostLEPscomprise the leaders of the local authority areas they cover - who are very much in the minority -plus a majority of self-appointed business people with no formal remit to represent a community or a range of sectors, no strict guidelines they are required to follow and, apparently, no compulsory reporting structures either upwards to government or downwards to the public which could result in any kind of retribution should the decision-making prove to be poor and/ or not in the best interests of society or the environment.
The vast majority of LEPs do not have other elected or social or environmental representatives on them. They are not transparent, not accountable and not democratic. (The suggestion exists in the current consultation document that they will “need to discuss with partners and government whether they have the legal vires and democratic responsibility” if they wish to take on budgetary responsibilities (para. 1.43) but this is wholly inadequate as a tether on these new institutions, especially considering how few democratic ‘partners’ they have). If they were merely advisory bodies, this would not be of major concern, but the government appears to be minded to hand them real planning and transport powers and funding.
The NW TAR sincerely hopes government will not give LEPs a final say in decision-makingbut, in any event, there should be a requirement that they have to comprise more elected representatives and also individuals who are appointed to specifically champion social and environmental agendas. This would be essential to ensure balanced outcomes. *Maximum 400 words
Part 2: This section of the consultation document explained the reasoning for providing assurances on governance, financial propriety and accountability for decisions. It also considered the options for the frameworks to support decision-making, meeting minimum quality standards on appraisal, and delivering value for money. It includesa proposed implementation timetable.
3.Do you have any thoughts or comments on assurance, in particular on whether there are any alternative ways of providing assurance other than putting in place some central criteria for local transport bodies to meet?
Response:The assurances are inadequate because:
(i)LEPs themselves are flawed entities (as described in earlier responses to this consultation) and therefore any bodies which include them – and not also representatives of the social and environmental sectors - will be flawed
(ii)There is no requirement for the most local level of elected representatives to be a party to the decision-making, ie. Town & Parish Councillors, who could be nominated by their regional federations and CountyAssociations to ensure that the most capable individuals are put forward.
(iii)Currently, robust guidance and controls are lacking. *Maximum 400 words
4.Do you have any comments in relation to how local transport bodies should demonstrate that they are accountable to central Government for tax-payers’ money and to local communities and citizens?
Response:There needs to be a high proportion of elected representatives on them, including Town & Parish Councillors, and there needs to be dedicated places for the Third/ Voluntary Sector and for the environmental sector if they are to demonstrate that they are properly representative. It is important they hold well-advertised meetings in public and have public speaking sessions and agendas and minutes are posted promptly on the internet along with details of the criteria against which the DfT is judging them and also a list of contacts and an explanation of complaints procedures. They must also be subject to FoI requests. *Maximum 400 words
5.Do you have any comments on the options for appraising and evaluating schemes, in particular in order to meet and test value for money?
Response:The issue of ‘value for money’ is emphasised a great deal but there is no requirement – as there should be - for economic impact assessments to be carried out on proposed projects. Quite often, perceived economic benefits are illusory. Evidence needs to be gathered to show that they are real.
There also needs to be health impact assessments to ensure that, for instance, high carbon-producing schemes are not endorsed in areas which are already Air Quality Management Areas. (Carbon off-setting is not the same thing and is not good enough in areas which are already failing to meet required standards).
*Maximum 400 words
6.Do you have any comments on the proposed implementation timetable, and any practical issues raised?
Response:The implementation timetable implies that the LEPs will automatically be a part of local transport bodies. As already indicated, NW TAR has serious concerns about this unless membership of the LEPs becomes more representative of society and so does membership of the transport bodies. If this is to happen, more time needs to be allowed for the appropriate appointments to take place than is indicated.
*Maximum 400 words
General questions
7.Do you have any general comments on proposals to devolve decisions and funding, and on any residual role for the Department?
Response:The establishment of Local Enterprise Partnerships was too rushed. Insufficient thought was given to their structure. This matters now that the government is minded to give them real powers and funding streams. Their membership and constitutions must be properly regulated and they need to be opened up to Town & Parish Council representatives, appointed by their regional federations and CountyAssociations, and to representatives from the Third/ Voluntary sector and the environmental sector.
The same comment applies to the transport bodies which are envisaged. This being the case, it is important that the business of both the LEPs and the transport bodies is conducted in a totally transparent manner. Meetings of the transport bodies must be advertised and open to the public and include a public speaking session and agendas and minutes must be posted promptly on the internet, along with details of the criteria against which the DfT is judging them and also a list of contacts and an explanation of the complaints procedures. It must be apparent to the public how they can influence decision-making on these bodies and the public must have the right of being able to make FoI requests of the new bodies.
It is also essential that the DfT keeps a very close watching brief on both the LEPs and the transport bodies to ensure they are giving due weight to Local Transport Plans, the sustainability agendaand the Climate Change Act. The DfT must have the power to withhold funding and/or intervene or take over a LEP or a transport body which is being run poorly. There must be a complaint procedure.*Maximum 600 words
8.Do you have any other comments on any of the other areas covered in the consultation?
Response:The government should pause and reflect on whether the new sub-regional transport bodies they are minded to set up would ‘add value’ to the present process and should consider how their deliberations would be dealt with in the planning system.
Any new transport bodies that are inaugurated, however constituted, must be given a brief to operate in a manner which aligns with the Climate Change Act, the government’s commitments to reducing greenhouse gas emissions and Local Authorities’ Local Transport Plans as well as their Local Plans. They should be required to take Air Quality Management Areas into consideration in their deliberations, to search for sustainable solutions to transport problems as a first priority and not to lose sight of the need to consider environmental limitsand social disadvantage in all their decision-making. *Maximum 400 words
Consultation Responses
Please send responses, using this consultation response template, via email to:
Mr Karl Murphy
Department for Transport
Great Minster House
33 Horseferry Road
London
SW1P 4DR
Phone: 0207 944 0079
Email:
Footnote: Response submitted on 19.3.2012
Response ID: ANON-Q4R8-PACG-A