West Midlands Business Council

The RPG Response:

The Needs for Business

December 2003

West Midlands Business Council          RPG Response      

                                                                                                                        Page

WMBC – A Partner for Growth                                                                    3

Executive Summary                                                                                      5

Chapter 1 – Introduction                                                                               11

Chapter 4 – Urban Renaissance                                                                12

Chapter 5 – Rural Renaissance                                                                  14

Chapter 6 – Communities for the Future                                                    16

Chapter 7 – Prosperity for All                                                                      18

Chapter 8 – Quality of the Environment                                                      21

Chapter 9 – Transport and Accessibility                                                    24

Chapter 10 – Implementation and Monitoring                                           26

Draft Regional Planning Guidance for the West Midlands

West Midlands Business Council - Response

The Needs of Business

WMBC – A Partner for Growth

The West Midlands Business Council (WMBC) is committed to ensuring there is substantial economic growth in the region and this can only be achieved with our regional and national partners.

It is in this spirit of co-operation that the Council, which is the only regional business representative body in the UK that comprises a range of national and regional business groups, welcomes the inclusive nature of this draft RPG process and congratulate the West Midlands Regional Assembly, the Government Office for the West Midlands and the Office of the Deputy Prime Minister for pioneering genuine partnership working.

The business community requires certainty and sustainability in planning if economic growth and regeneration targets for the public and private sectors are to be met.  Without these two principles, an uncertain planning environment can only lead to confusion and, inevitably, negative cost implications for business and, therefore, for the regional economy – with the negative national economic repercussions that this implies.  That is why WMBC welcomes the fact that RPG has a clear long term vision for the planning needs of the region.

There is, though, a need for fairness in the planning system to reflect the various interests in society, including the business interest which is so vital to driving forward the regional economy and, therefore, helping to fund high quality public services.

Therefore, our main areas of concern with the Office of the Deputy Prime Minister's (ODPM) response can be classified in the following areas:

• RES – There needs to be an explicit reference to the Regional Economic Strategy (RES) in each of the chapters – not just in the Prosperity for All Chapter.  Such a clear commitment to bring in RPG with the RES would avoid needless duplication in policy implementation and would ensure that all major regional strategies complement each other and, therefore, lead to coherent policy development and implementation for the region;

• Milton Keynes – The impact of the Milton Keynes growth area on the southern edge of the West Midlands region could have significant repercussions for the planning direction as stated in the RPG.  Already the West Midlands region is experiencing some difficulties with the strong growth of the south east economy leading to high house prices in the southern part of the West Midlands with a fear of a lack of affordable housing for essential workers.

Such strategic difficulties could be exacerbated by the Milton Keynes growth area.  Not only could house prices be affected but migration out of the region and the skewing of transport priorities towards the new growth area could severely impair the economic growth potential of the West Midlands region.

Though WMBC is committed to a healthy regional economy in London and the south east to help sustain the West Midlands regional economy businesses believe that the medium and long term impact of the Milton Keynes growth area should be reflected in RPG. 

Therefore, WMBC proposes that in each chapter of the RPG it is stated that the policies contained in each chapter are subject to review within the context of a sustainability impact study carried out by a cross departmental group, with the full and equal participation of the West Midlands regional parties, including the business community, to analyse how the growth of Milton Keynes will impact upon the socio-economic circumstances of the West Midlands region.

• Transport – WMBC welcomes the re-ordering of the transport priorities in the Transport & Accessibility chapter.  This change is a reflection of the fundamental need for transport infrastructure in the region to be significantly improved.  WMBC regrets, that firm practical proposals are not contained in this chapter to improve the transport infrastructure.  It is the poor state of transport in the region which is not just stifling business growth but is leading to serious and detrimental cost implications for the region.  Therefore, WMBC calls for this chapter to reflect the needs for urgent remedial action, at the very least, by calling for the chapter to include a section stating that an action plan for transport improvements should be drawn up with the relevant Government departments with the regional institutions within six months of the definitive version of RPG being published.

• Monitoring – WMBC applauds the ODPM for its recognition that the current monitoring arrangements for RPG are inadequate.  WMBC also welcomes Government action in this area.  WMBC is committed to working with the ODPM, Government Office, the Regional Assembly and other partners to ensure that the future monitoring process fully involves all stakeholder partners, including the business sector.

The West Midlands Business Council is committed to adopting a positive role with partners to achieve, together, the very best for our region.

Executive Summary

Below is a summary of WMBC recommendations

'Chapter One' – Introduction

Paras 1.5, 1.10 – WMBC welcome the recommendations that the role of the Regional Planning Body should be clarified.  This will help ensure that the position of the RPB can be taken into full consideration by local authorities and avoid confusion in the planning process.  WMBC recommends that due to the vital role of business in the planning process, that the role of business representatives on the RPB is emphasised.

Paras 1.19, 1.30 – WMBC notes that the Milton Keynes growth area may mean that "patterns (in the West Midlands region) might be affected.  WMBC calls on RPG to reflect in each chapter the need for a review in the context of the Milton Keynes development (for more on this, see introduction). 

Para 1.33  - WMBC fully welcomes the description of the link between RPG and the Regional Economic Strategy (RES)  as "critical".  WMBC calls for the linkage of the RES to RPG to be clarified in each chapter.

'Chapter 4 – Urban Renaissance'

Para 4.1 – WMBC agrees with the observation that a growing number of people are leaving the MUAs and this is leading to negative economic repercussions.

WMBC calls for a coherent Regional Marketing Strategy to help address this issue.  WMBC calls for the ODPM and the regional institutions to work towards the instigation of professionally run private rented sector, as in the United States and in a number of EU member states.

Para 4.10 – WMBC notes the observations in this paragraph and calls for a review  of regional support mechanisms for SMEs to accompany the RPG process.

Para 4.15 – WMBC positively endorses the linking of the Regional Cultural Strategy with economic benefits.  WMBC calls for this to be clarified in order for the issue of tourism in urban areas to be emphasised and thereby linked to the Regional Cultural Society and the RES.

Policy UR 2 – WMBC supports this policy and adds that affordable housing for essential workers is vital to address regional needs. Work should also be undertaken to support a professionally run private rental sector (see above).

Para 4.16 – WMBC agrees with these observations and calls for the establishment of a protocol to avoid confusion in partnership working.

Policy UR 3 – WMBC welcomes this policy but would add that it is not only the public sector agencies who should work more closely together to deliver public service but that such co-operation should involve the business sector.

Policy UR 4 – WMBC welcomes the policy.  It is in this context that WMBC urges an addition to this policy to specifically include English Partnerships as one of the agencies involved to address poor economic performance, especially in the Telford context.

'Chapter 5 – Rural Renaissance'

Para 5.7 – WMBC welcomes the commitment given to local community involvement in economic plans.  WMBC believes that for such plans to be successful there should be an addition to this section to include 'locally based businesses'.

WMBC would add three further policies to strengthen the policy direction of this chapter.

• Extension of broadband into rural areas and a target for this extension to be included in RPG;

• Utilisation of brownfield sites in rural areas is needed as much as in urban areas.

• Utilisation of property in rural areas for economic growth potential.

'Chapter 6 – Communities for the Future'

Policy CFI1– WMBC welcomes the policy as business have much interest to ensure there is affordable housing available for essential workers.

Policy CF2 – WMBC welcomes this policy and adds that English Partnerships should be specifically mentioned, particularly in relation to Telford.

WMBC would add three further policies in relation to this chapter:

• Work to ensure there is a regional professionally run private rented sector, which would help ease the regional housing difficulties.

• WMBC recognises that the issue of housing is tied to PPG3 and that PPG3 should be able to be fully corporated into the definitive version of RPG;

• PPS7 recognises the concept of essential workers in respect of affordable housing and this should be incorporated within RPG.

'Chapter 7 – Prosperity for All'

Policy PA1 – WMBC notes this policy and would add that WMBC recognises that the Major Urban Areas (MUAs) should be the main drivers of economic growth but that the RPG should also recognise there are other drivers of economic growth in the region such as rural business and market towns.  Therefore, when planning issues are being considered, the need of areas outside MUAs should also be recognised within this overall context.

Part d, Policy PA1 – WMBC agrees wholeheartedly with the aspiration of raising skills levels in the region.  WMBC notes there is substantial work that needs to take place before practical targets can be set.  Therefore, WMBC urges that this section of the RPG is reviewed within six months after publication of RPG.

Policy PA12 – WMBC welcomes the aspiration of the strengthening of air and rail links to Birmingham and calls on all relevant statutory partners to form a joint action plan within six months of the RPG being published for this to be achieved.

Deletion of Policy PA13 – WMBC understands the decision of the ODPM to delete this policy, as it was considered to be more appropriate for the RES.  WMBC would state, though, that for the RES to be truly effective some reference to cross educational institutional working to develop a skills policy should be incorporated in some form in this chapter.

Para 7.66 – WMBC notes this paragraph and notes that as the Black Country Study will impinge on the need for a coherent Regional Transport Strategy, that the terms of reference of the Study should reflect this reality.  WMBC also calls for a full, active and equal role for businesses of all sizes in the Black Country to be involved in this study.

Targets Regime – WMBC is very concerned at the setting of targets in this chapter.  The statement that "100% of all employment land provision to be in locations accessible by walking/cycling/public transport" is not just unrealistic in not reflecting commercial realities but would be harmful for regeneration work in the rural economy.

WMBC calls for targets that reflect a new policy direction to be incorporated in the chapter with supplementary explanatory test.  This would also include, what WMBC considers is the commercially unrealistic target that "a minimum of 65% of new  employment generating development to be on previously used land" – a policy that we believe does not reflect the rural agenda.

In respect of targets in general, WMBC propose that such targets should involve a Regulatory Impact Assessment, as produced for Parliamentary Bills.

'Chapter 8 – Quality of the Environment'

8.97 – Clarification is sought as to whether the Region should work towards achieving a regional targets equivalent to the national targets and not agree to go further than this i.e. compensate for under achievement by other Regions  and whether the regional target should be less than the national target.

8.98 - The existing UK Climate Change Programme documentation includes a caveat that targets for electricity from renewable sources are subject to an economic test "subject to the cost to consumers being acceptable". This wording is not reflected within the RPG draft and is important since the responsibility for achieving the targets will not rest with the customer groups affected.

Absolute targets for CHP need to be supported by more detailed definitions since the type, efficiency and fuel types can make a fundamental difference to the investment, payback and outputs from the schemes.

Clarification is also sought on whether the 'domestic in point three refer to local consumers within West Midlands homes or the UK as in GDP

We also believer there could be reference in this section to the renewable energy sources that can be cost-effectively deployed within the region.

8.99 -  In reference to the statement "In 2000, the West Midlands generated less than 0.1% of its consumption from renewable sources.....could provide in excess of 15% of Regional needs" we believe this statement needs to be clear as to whether it refers to consumption or generating capacity.

Based on the assumption that there will be no growth in consumption over 20 years from 2000 – 2020, this requires a 150 fold increase in renewable generation. Given the current starting point, we propose a 5 fold capacity increase and 3 fold increase in output could be a stretch target for 2010.

There is scope for development of CHP schemes but the target total should be a pro-rata percentage for the West Midlands as a proportion of the National energy consumption.

8.100 – Clarification is sought on what assumption the 15% estimate was arrived at.

We would also seek guidance concerning generation from Waste incineration as it forms the largest percentage of renewable generation within the West Midlands. Current legislation together with the Regional Planning Guidance does not appear to be consistent and therefore clarification of this section would be appreciated.

8.104 – While welcoming this approach, the whole topic of planning location and urban development brings to the fore the topic of transport planning and its impact upon greenhouse gas emissions. Therefore this, we recommend, highlights the need for a Regional Emissions policy.

Policy M1 – WMBC welcomes this policy.  Due to possible changes in the availability of minerals, WMBC proposes that the target for land banks provision of permitted reserves of non-energy minerals is reviewed annually, within the context of the need for environmental sustainability.

WMBC recognises that the West Midlands is one of the best and most informed Minerals Planning Authorities in the country and we support the continuation of this work.

'Chapter 9 – Transport and Accessibility'

WMBC welcomes the re-ordering of the transport priorities in this section.  WMBC believes this reflects the urgent need to address the poor state of transport infrastructure in this region, which is damaging the regional economy.