AGMA CHIEF EXECUTIVES

STRATEGY GROUP

11 NOVEMBER 2005

CONSULTATION ON INTERIM WORKING DRAFT RSS:

INITIAL AGMA VIEWS

1 Purpose of Report

Chief Executives will be aware that a first working draft of RSS has been prepared by the NWRA for “informal consultation”, a process which precedes the more formal consultation commencing in March of next year.

The RSS Board approved the consultation draft of RSS as a means of ensuring that the RSS process stayed on track, but without prejudice to any position of support or objection which the local authority partners might have with the document.

The current informal consultation process ends on 25 November, the date of the next AGMA Executive meeting. A full report will be made to the Executive at that meeting. The purpose of this short report is to give Chief Executives a “taster” of the emerging view of a sub-group of AGMA planners on the draft.

2 The consultation process

The current consultation process has been described as limited, but in fact seems to be involving over 3000 organisations. The draft may be seen as gaining some status through this process, and it may well be that if AGMA has serious concerns at this stage then these will need to be expressed in strong terms.

The consultation itself is an on-line process run by consultants, and provides an opportunity for consultees to respond on each draft policy in RSS (a process of going through some 90 on-line pages of questions). It is considered that AGMA should not respond through this mechanism – wherein strong concerns may get “lost” – but should instead respond by letter at a more strategic level.

3 Content of draft RSS

AGMA planners have the following concerns about the consultation draft:

3.1 General

* There is no section of the document which sets out an overview of the regional strategy, to provide a framework for the topic based sections and the sections on the city regions. The RSS steering group has agreed – at the suggestion of Steve Weaver - that this should be done, within the context of a reorganisation of the structure of RSS. There has been no time to do this prior to the consultation process commencing, but it is suggested that AGMA should reinforce the message that this is an absolute essential requirement. Such a section should give some indication of where real priorities lie.

* RSS has elevated status as part of our development plans, and the new planning documents which all authorities are required to prepare must “conform” to it. It is therefore important that it is fit for purpose, particularly in terms of policies and their justification. At this stage we do not think it meets this requirement, for a whole series of reasons. Most policies are statement of intent (“plans and strategies… should/will… ”, “local authorities should...”). They are sometimes poorly written and unclear, with little clarity about how they will be used, and at times state what we are or should be doing in any event. We would have preferred RSS to have adopted a much more direct approach (“development should/will”, “the following areas will be protected …”), which would assist clarity. The wording of all policies requires substantial scrutiny and testing, and in many cases re-drafting.

* Policies for the city regions have been incorporated based on what each sub region has submitted. These sections need to be looked at very carefully, as the approach currently looks unbalanced and un-integrated. There is an onus on ourselves to review the Manchester city region section (taking account of the need to ensure policies are well written and clear), but also to look at the other city region statements very carefully.

* There is currently no technical justification to most of the draft. This is partly because of problems of preparing this in the timescale, but it is also unclear how far an adequate evidence base has so far been developed. It is essential that this is brought together over the period leading up to the submission of the formal draft to GONW.

3.2 Key topic areas

The following illustrate some of our initial comments on key topic areas.

3.2.1 Housing

The housing policies as currently drafted do not address the key housing priorities of the region and do not fully support the agreed approach outlined in the Manchester City Region Sub Regional Statement.

·  there is no mention of the critical relationship between housing and economic growth;

·  the Regional Housing Strategy is not referred to;

·  the sub-regional priorities and spatial framework outlined in the Spatial Development Framework chapter are not reflected;

·  there is an over emphasis on setting out issues that local authorities need to address (many of which are already being carried out) without providing any strategic context for housing policy; and

·  there is no accompanying technical justification, strategy or evidence for the scale and distribution of new housing supply around the region.

In general criticism of the housing policies (L1 – L5) could be made at length, and this is inappropriate in this report. On a more positive note, housing is an area where revised policy wording could be developed, based on the thinking already agreed by AGMA in the MCR Sub Regional Statement, and offered to the NWRA.

3.2.2 Employment

The accelerated review of RSS was in part required by government to align the RSSs for the northern regions of the UK, with the Northern Way. It is a matter of concern, therefore, that the draft RSS employment policies (W1- W3) do not take sufficient account of the Northern Way's key driver: to reduce the productivity gap with the rest of the UK. Instead broad locations for employment sites are identified, largely carrying forward existing regional sites. This fails to provide the scope or flexibility to allow the city regions to review their existing employment land provision (regional & local sites), to identify and bring forward a suitable range of quality sites in LDFs, that meets the site requirements and locational demands of the key growth sectors.

It is suggested that these policies should be rationalised to one or two criteria-based policies, focused on raising GVA across the region and requiring identification of employment sites that meet forecasted demand at a sub regional level, to be delivered through LDFs.

Whilst it is known that Greater Manchester only has 12 years employment land supply, a fundamental gap in our knowledge is whether our existing supply of land is of the right quality and in the right locations to meet forecasted demand. It is advised that AGMA should consider the need to commission an assessment of existing employment sites, building upon the findings of the current ME/AGMA Market Demand For Employment Sites Study.

3.2.3 Transport

Transport is an area where the lack of strategy and of priorities in the draft has a direct impact. Draft policy RT8 is intended to set priorities for transport investment and management, but is fundamentally inadequate and inappropriate. The other transport policies are a mix of development control criteria (which should be in the Spatial Development Framework) and guidance which adds little to existing best practice or national guidance.

Our expectation is that the RSS transport policies will set out the priorities for investment to support the Manchester city region strategy; at present they do not do this.

3.2.4 Waste

The waste management policies in the draft are a major step backwards from the policies which had been developed through the Partial Review of RSS. It is considered that they do not provide an adequate planning framework for dealing with waste, and will not properly inform the preparation of waste DPDs.

4 Conclusion

In view of the depth and range of concerns about the draft RSS, our view is that it is highly unlikely that the document can be put into a form which is “fit for purpose” by the current scheduled date of submission to Government (January). At that point Government takes control of the process. In essence the draft needs to be re-written in major respects, and it is unclear from outside the NWRA how easy/difficult it will be to remedy this situation, and what timescale will be required. In the first instance it is considered that an extension of the timetable for submission is requested, and further thought be given to how much time is required.

Recommendation

That Chief Executives note the initial views of AGMA planning officers on the interim working draft RSS, and advise on how this should be taken forward in the report to AGMA Executive.