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North Lincolnshire Council considers that for the purposes of delivering sub-regional economic development that the NUTS3 geographic area be considered the functional economic sub-region and not the NUTS2 area. This will result In North Lincolnshire Council together with North East Lincolnshire Council working together as a sub region. This area properly reflects the nature of functional spatial relationships and dynamics in relation to the economy, housing and transport it is considered the most appropriate spatial economic area for the following reasons: " The South Humber Bank is an economic opportunity of national importance located with the boundaries of both North and North East Lincolnshire Councils. " The South Humber Bank is already the busiest UK port (it includes South Killingholme, Immingham and the Grimsby ports complex) and is the last undeveloped strategic water estuary in the country and the largest employment site in the region (1,000ha) with more than 5billion of future investment and 15,000 jobs evidenced. The two councils are to shortly create a new partnership structure with the Regional Development Agency  Yorkshire Forward to deliver this investment. Much of the two council s previous LABGI reward has been as a result of this activity and future reward could be used to stimulate and incentivise the current unprecedented amount of inward investment opportunities based around ports, renewable energy, chemical and bio fuel growth. " North Lincolnshire and North East Lincolnshire Councils have contiguous geographic boundaries and the Travel to Work and Travel to Learn areas are almost coterminous. The council already work cross border on many issues because of the shared geography. This includes working together to deliver a Joint Housing Strategy, Shared Gypsy and Traveller studies, Joint Strategic Flood Risk Management Plans, shared procurement arrangements and jointly funded economic policy and regeneration posts. " The council s have a history of working together on major economic initiatives including the tripartite development of the Humber Seafood Exchange / Humberside International Airport Perishables Hub and Seafood Institute. " The Humber / Hull and Humber City Ports Region is a distorted and not a fully functional sub-region because of the physical divide of the River Humber and the fracturing of shared economic activity created by the Humber Bridge tolls. This results in an almost total absence of economic migration and two separate labour markets as well as a restriction of flow of goods and services between the two banks of the river. The East Riding of Yorkshire Council and Kingston upon Hull City Council that form the remainder of the NUTS2 (Humber sub-region) are located on the north side of the River Humber and do not share contiguous boundaries. Furthermore there is virtual no shared economic relationships as the cost of the Humber Bridge tariff (the highest in the country) creates a distinctive separate north and south Humber economic geographies. This presents few opportunities to use LABGI to incentivise economic growth capacity or to influence and derive funding partner benefit at this greater Humber spatial level. qAlthough the District has strong economic links with the Liverpool City Region and Wigan Borough within the Manchester City Region, for administrative purposes, the Council would recommend inclusion within Lancashire. In response to a request for clarification from CLG: I confirm that, on balance, the Council wishes to be placed in the NUTS2 Lancashire sub-region. 4West Sussex CC regards itself as being of sufficient economic size and weight to be a viable sub-region in itself, along with its Districts and in keeping with the criteria the consultation paper sets out. We see no particular advantage or reason to support the suggestion advanced in the consultation that the NUTS2 categories be applied to the sub-region i.e. including West Sussex with Surrey and East Sussex. The economic make up of all three counties has significant differences. For example, East Sussex has lower average pay for full time workers than West Sussex (8% less per Governme< nt s NOMIS data) reflecting its different labour market (greater reliance on hotels and catering and much less on Finance, IT and business than the South East average). Given the lack of economic commonality, we believe it would make more sense to judge West Sussex as a discrete economic unit. We believe the scheme makes most sense at this lower level, in terms of the connection and accountability between the efforts of local authorities and the potential rewards available. Westminster considers that it should be combined into a separate sub region with the other five Central London boroughs (City of London, Camden, Islington, Kensington & Chelsea and Southwark) with whom it shares common economic characteristics and an established economic development partnership. The five logical LABGI sub regions for London linking into established economic development partnerships already in place would therefore be " the six Central London Forward boroughs (comprising Camden, Kensington & Chelsea, Islington, City of London, Southwark and Westminster) " the West London Alliance - http://www.westlondonalliance.org/ (comprising Brent, Ealing, Hammersmith & Fulham, Harrow, Hillingdon and Hounslow) " the South London Partnership - http://www.southlondonpartnership.co.uk/home.aspx (comprising Bromley, Croydon, Kingston, Lambeth, Merton, Richmond upon Thames, Sutton and Wandsworth) " the Thames Gateway London Partnership boroughs - http://www.thames-gateway.org.uk/ (comprising Barking and Dagenham, Bexley, Greenwich, Hackney, Havering, Lewisham, Newham, Redbridge, Tower Hamlets and - due to the fact that it is one of the five Olympic host boroughs Waltham Forest) and " the North London strategic alliance - http://www.nlsa.org.uk/about.php (comprising Barnet, Enfield and Haringey) This sub regional geography would be consistent with our view that the LABGI reward should reflect each authority s contribution to the national economy and the LABGI reward should continued to be calculated at a local (if not individual authority) level using recognised regions where there is clear evidence of an economic development partnership infrastructure already in place..Our NUTS2 region is Hampshire and Isle of Wight. Whilst there is much joint working between authorities in this area, Hampshire and the Isle of Wight do not make up a single, economic unit. Rather, there are as number of economic sub regions within this area, such as the PUSH sub region, which has very different characteristics to rural mid-Hampshire. We do, however, work with other Hampshire authorities through the Hampshire LAA. The Winchester District presents a more complex pattern of economic characteristics than other Hampshire districts, with the special needs of the city in particular not being matched by others in the sub region In response to a request for clarification from CLG: We would like to reiterate that we would rather not be part of a grouping as we object to the proposed new county/district split as indicated in our response. However, in the event that the sub regional approach goes ahead we would prefer to be part of a PUSH grouping, even though a small part of the Winchester District does not fall into the official PUSH boundaries, because the bulk of our economic growth is likely in the southern part of the district which does fall within the boundaries. Finally, as a third choice, we would consider a rural Hampshire cluster with Test Valley, East Hants and New Forest DC.In Berkshire there are extremely close economic interdependencies between its six component local authorities. This is reflected in pronounced relationships betwee travel-to-work, travel-to-education, travel-to-retail and business clustering. Conversely there is little documented evidence of economic collaboration betwee Berkshire at the southern extreme of the NUTS2 area and Milton Keynes to its north. This grouping is further supported by the recent creation of the Berkshire Economic Strategy Board (BESB), the sub-regions strategic economic partnership, which has the six Berkshire Unitaries at its core. BESB recently adopted its Sustainable Economi Prosperity Strategy for Berkshire, based on shared challenges and objective facing th sub-region, further underlying the collaborative approach to economic development. This demonstrates an infrastructure currently in place which can be utilised to suppoi and nourish economic growth and development within and amongst the County authorities. Such a support structure is not, nor is likely to be, in place for the propose NUTS2 sub-region. Our strong preference, supported by all six Berkshire Unitary authorities, would be for Berkshire County sub-region.Wirral considers the local authorities of Halton, Knowsley, Liverpool, St< Helens and Sefton are in the same sub-region for the purposes of cooperation in economic development. This sub-region meets the criteria stipulated in the consultation, in particular the authorities are contiguous and the proposed sub-region would not be anticipated to change in the foreseeable future. Further there is a history co-operation in economic development between the authorities and the MAA being developed for the sub-region covers the six authorities.In Berkshire there are extremely close economic interdependencies between its six component local authorities. This is reflected in pronounced relationships betwee travel-to-work, travel-to-education, travel-to-retail and business clustering. Conversely there is little documented evidence of economic collaboration betwee Berkshire at the southern extreme of the NUTS2 area and Milton Keynes to its north. This grouping is further supported by the recent creation of the Berkshire Economic Strategy Board (BESB), the sub-regions strategic economic partnership, which has the six Berkshire Unitaries at its core. BESB recently adopted its Sustainable Economi Prosperity Strategy for Berkshire, based on shared challenges and objective facing th sub-region, further underlying the collaborative approach to economic development. This demonstrates an infrastructure currently in place which can be utilised to suppoi and nourish economic growth and development within and amongst the County authorities. Such a support structure is not, nor is likely to be, in place for the propose NUTS2 sub-region. Our strong preference, supported by all six Berkshire Unitary authorities, would be for Berkshire County sub-region. FThe Council has strong links with the other Black Country districts (Sandwell, Dudley & Walsall) however the wider links and the impact of the West Midlands area is of significant importance. That for the purposes of LAGBI the sub region should be treated as the whole of the West Midlands area (i.e the 7 district councils).Worcestershire County on its own. There are varying definitions of the  sub-region being proposed in different policy/strategic documents which potentially confuse and influence local authority activities. It is suggested that if one definition is to be used then it should be co-terminus with existing and forecast government arrangements e.g. the Sub-National Review of Economic Development and Regeneration and Local Area Agreements. Within these proposals Worcestershire, like any other upper tier Authority, has been identified as a Sub-Region and should therefore be considered as such for the purposes of managing the LABGI funds. In the West Midlands region Worcestershire cooperates with several Local Authorities within the context of Economic Development depending on the common projects/priorities. We already work with partners outside the sub-region where there are similarities; we do not want to force similarities. For example Birmingham and Worcestershire are different yet where there are common themes both authorities work with each other as partners. Examples include the Central Technology Belt and the Longbridge Area Action Plan. Wyre Forest District Council is logically part of the Worcestershire Sub Region and would propose that any LABGI grant distribution is based only on the Worcestershire administrative area which provides logical synergy with the developing proposals for the role of the County Council through the Sub National Review of Economic Development and ties in with the priorities set out in the Local Area Agreement and within the Worcestershire Partnership.Northumberland UA Northumberland UA* Wiltshire UA Shropshire UA No preferenceNo opinion expressedNorthumberland UAThe  Sub-Regional Responses worksheet is a list of all local authorities, organised by NUTS2 areas (merely so that authorities in the same part of the country appear conveniently close together in the list). Responses from county councils are grouped together at the bottom of the worksheet. Column C, headed  Suggested sub-regional partners lists the local authorities which the respondent authority has suggested should be in the same LABGI sub-region as their own authority. Column D headed  Other LAs that include respondent in their suggested sub-region lists the authorities that have said they see themselves as being in a sub-region with the respondent authority. Please note that:g The Council has some fundamental concerns about the proposed reforms which centre around (1) The proposed area groupings (NUTS2) (2) The proposed apportioning of any award between the District and County Councils. It is felt that both of the above will have a detrimental effect on lower tier Councils in terms of a loss of incentive to devote time, effort and considerable resources to encouraging business growth in return for a far smaller share of any award that may be given. Firstly, it is felt that the area to which it is proposed that Wellingborough belongs (Northamptonshire, Leicestershire and Rutland) is too wide, both in terms of its geographical si< ze and the marked differences in terms of characteristics of the area. This could result in a lack of accountability for efforts made by individual authorities on economic development and potentially an unfair distribution of monies awarded that may not be an accurate reflection of efforts made. As an area with a relatively small population, Wellingborough would stand to lose out substantially in financial terms under the proposed system compared to the current scheme. Yet, Wellingborough is committed and extremely proactive in its approach to the economic development of the Borough and would not wish to see those efforts being undervalued purely on the grounds of population level. Indeed, areas such as London will benefit greatly under the proposed scheme due to its vast population, when one of the main purposes of the Growth Areas (Wellingborough is part of the Milton Keynes South Midlands Growth Area) is an attempt to halt the  overheating of London. It could be viewed that the proposed reforms to the LABGI scheme contradict this aim and areas that are earmarked for growth will lose out on valuable funding which could be used to achieve the fundamental aims of the Growth Areas. If the allocation of resources were to be made at a higher level we would argue that this should be at a level no higher than sub regional, in Wellingborough s case this would be North Northamptonshire, as the economic development case is clearly defined through an economic action plan and organisations such as North Northamptonshire Development Company are already in place to minimise the bureaucracy of allocating funds against prioritised projects. In response to a request for clarification from CLG: The North Northamptonshire sub region is Wellingborough, Corby, Kettering and East Northamptonshire. North Northamptonshire Development Company has also been formed to help deliver the growth and employment issues and responsibilities are shared with Northamptonshirte Enterprise Ltd.Linking the reward to sub-regional performance blurs the boundaries between individual Local Authority economic performance and reward. Reduced grouping would allow better connections to be made with LAA targets for economic growth. As a consequence, sub-regional groupings should not be overly large. Most economic development at a sub-regional level has taken place across the Black Country, incorporating the four authorities of Dudley, Sandwell and Walsall Metropolitan Boroughs and Wolverhampton City Council. The Black Country Consortium works with the four Black Country authorities to assist in the alignment of strategic objectives. Although the City Region (Birmingham, Coventry, Dudley, Sandwell, Solihull, Telford, Walsall and Wolverhampton) also plays a key role in certain areas of economic development (e.g. worklessness through the City Strategy Business Plan), this area should be considered too large a sub-regional grouping and would add additional political complications over distribution. ~Warwick District Council (WDC) is committed in partnership with the following local authorities as part of the Coventry, Solihull and Warwickshire sub-regional partnership: " Stratford-on-Avon District Council; " Nuneaton and Bedworth Borough Council; " Rugby Borough Council; " North Warwickshire Borough Council; " Warwickshire County Council; " Coventry City Council; " Solihull Metropolitan Borough Council. This group of local authorities have come together in a strategic economic development partnership of CSWP Ltd. It is, therefore, the sub-region in which WDC belongs to for the purpose of cooperation in economic development.~The functional economic geography where Warwickshire naturally sits is the Coventry, Solihull & Warwickshire sub-region. Strong partnership arrangements already exist for this area, including the CSW Forum (an elected member-led body) and Coventry, Solihull & Warwickshire Partnership (a strategic partnership of public, private, voluntary sector and education bodies established to promote the economic regeneration of the area), leading to joint approaches to economic development, regeneration, planning and housing growth, waste and transport policy. This functional economic area was also recognised and confirmed through research undertaken for the LGA ( Prosperous Communities II ) to map sub-regions based on housing market areas, travel to work areas, and markets for six key sectors of the economy. The draft Regional Spatial Strategy (RSS) Phase 2 revision also recognises the functionality of the Coventry and Warwickshire sub-region and the close< links that Solihull has to it for spatial planning, economic development, housing and transport. This position is also supported by the District and Borough Councils in Warwickshire. Wakefield sits at the heart of a city region including the local authority districts of Barnsley, Bradford, Calderdale, Craven, Harrogate, Leeds, Selby, and York. These councils, together with North Yorkshire County Council have worked together over a number of years, cooperating to put in place a Comprehensive Regional Development programme in 2006, contributing to the Regional Economic Strategy for 2006-2015, and developing a pilot Multi-Area Agreement (MAA) signed off in the summer of 2008. The MAA recognises that shared economic priorities such as tackling high level skills gaps and reducing transport congestion are best delivered collectively by cutting across traditional administrative, partnership and functional boundaries. It is unusual that the preferred sub-regional geography set out in the consultation is based upon the NUTS classification rather than upon city regions or even travel to work areas. There is the problem that some parts of the country are not in a city region and also that some districts e.g. Barnsley are in two city regions so that double payment would need to be avoided. There seems to be no strong argument for using the NUTS 2 classification for areas outside London. The arguments for adopting the NUTS 3 classification, which would place Leeds in a  region by itself, could also be proposed and would remove some of the anomalies in NUTS 2 that create artificial  sub-regions such as  Leicestershire, Rutland and Northamptonshire , which do not reflect real world linkages. The relevant NUTS 3 area for Wakefield, however, includes Kirklees and Calderdale which is also not a real world economic entity, given the stronger economic and travel to work linkages between Wakefield and Leeds than Wakefield and Calderdale. It may well be that the relevant NUTS 2 region for Wakefield which is the West Yorkshire group of districts has advantages over the alternatives in terms of economic entities. Another alternative could be to dispense with the regional approach altogether and to treat districts as individual economic entities for the purposes of the new scheme, as was the case under the old scheme. This has, however, in the past shown marked variations in rewards between districts. If Government is looking for an economic unit larger than districts but smaller than city regions, then there is the Travel To Work Area which has a statistical basis in self containment factors of workforces. Wakefield and Castleford form a distinct Travel To Work Area in the current TTWA map as produced by the Office for National Statistics. The problem with all of these alternatives is that because the national totals are limited any alternative groupings, including a geography based on city regions or NUTS 3 areas, would necessarily create  winners and  losers , and risk pitting authorities against one another. In response to a request for clarification from CLG: Kirklees should be included. The consultation document asks  in the spirit of the Sub-National review for local authorities to propose which sub-regional groupings we feel would be most appropriate for us. It is noted that the suggestion is that authorities should be grouped according to the NUTS2 categories used by the European Union. This proposal links Surrey Heath with the rest of Surrey and East and West Sussex. It is this Council s view that Surrey Heath should instead be linked with Hampshire/Isle of Wight. We believe this for the following reasons: Surrey Heath sits at the northernmost tip of Surrey and its functional economic zone is very clearly the adjacent authorities of Hart and Rushmoor in Hampshire and Bracknell Forest in Berkshire; Surrey Heath has had initial discussions with these authorities, as well as those in Reading, Basingstoke & Deane and Wokingham regarding the development of a Multi Area Agreement. This is an issue all of the listed councils are keen in pursuing and we will be looking to develop an agreement over the coming months. Surrey Hea< th is contiguous with these authorities (Hart, Rushmoor and Bracknell Forest in particular), which is a requirement of the Government s invitation to self select sub regional areas; Surrey Heath has far more in common with Hampshire/Berkshire than it does with the southern end of Surrey and certainly with East and West Sussex. By way of example, Famborough Airport sits within Rushmoor, very close to the border with Surrey Heath. Should there be any changes to this airport in the coming years, such as expansion, there would be a significant impact on the local economy and economic prosperity of Surrey Heath. However, should Gatwick Airport in Sussex expand the impact on Surrey Heath would be largely unfelt.Tameside is within the NUTS2 sub region of Greater Manchester which co-ordinates its economic development through Manchester Enterprises Ltd. The GM sub region has recently agreed a Multi Area Agreement with government which proposes to co-ordinate and deliver the following key blocks of activity across the sub region: " The Greater Manchester Strategic Plan " Reducing Worklessness " Strengthening our Skills Offer " Achieving more for 14-19 year olds " Accelerating Business Expansion to Generate Growth " Enhancing Investment, Knowledge and Innovation " Ensuring the city region s critical infrastructure will sustain our economic growth (covers infrastructure and transport) " Meeting the Housing Needs of a competitive city region =Teignbridge is a member of the Exeter and Heart of Devon sub-regional partnership which consists of Mid Devon, East Devon, and Teignbridge District Councils and Exeter City Council, the private sector and other major organisations. These all work together to contribute to the economic development of the sub-region. lTelford and Wrekin collaborates and works jointly with neighbouring authorities to deliver economic development. The economic performance of local areas, cities and regions is inter-related and joint working to face common challenges brings benefits to a whole area. Working as part of the City Region is key to Telford & Wrekin s ability to promote economic development. We therefore propose that Telford & Wrekin should be part of a City Region sub-region for the purposes of LABGI. The suggested sub-region would be: Birmingham, Coventry, Dudley, Sandwell, Solihull, Walsall, Wolverhampton and Telford & Wrekin. tTendring District Council is a partner of the Haven Gateway Partnership along with the following District Councils, Babergh, Ipswich and Suffolk Coastal. The partnership is based around the five Haven ports of Felixstowe, Harwich International, Harwich Navyard, Ipswich and Mistley and provides an opportunity for partners to work together to promote economic opportunities and secure the future prosperity of the region. Therefore, in many respects, Tendring has stronger links with the authorities identified above as a sub-region in terms of cooperation in economic development than with other district councils in Essex. We believe that the LABGI reward should be based on growth within individual districts (as under the original scheme) rather than a multi district reward being allocated to districts based on population. This approach would negate the need for sub-regions. Thanet District Council is part of The East Kent Local Strategic Partnership together with Dover, Shepway and Canterbury and these Councils together with Kent County Council would be our main local authority partners for economic development. It should be noted that this is not an agreed sub-region for any revised LABGI scheme. However if we were required to be grouped with other districts, the Kent wide grouping based on the NUTS2 grouping is felt to be too large and we would prefer a more East Kent based grouping to be considered . ~While we can accept the proposal put forward we believe that a more accurate sub region for Torbay would see a grouping with South Hams and Teignbridge. This is because the three areas form a natural economic sub region encompassing the wider travel to work and travel to learn areas. This is increasingly recognized by our regional partners as forming a southern Devon sub region Trafford is clearly, geographically, in a sub-region with the nine other Greater Manchester authorities, and this has been further consolidated by the recent collaborations in terms of multi area agreements and local area agreements etc. Although Trafford identifies with some local authorities (e.g. Manchester) more than others, we agree that this method seems the most appropriate method of grouping.bIn terms of cooperation in economic development Tunbridge Wells has a strong existing working relationship with Tonbridge & Malling and Sevenoaks Councils under the umbrella of the West Kent Partnership and therefore into the Kent area. It should however also be recognised that Royal Tunbridge Wells together with Tonbridge is identified in the Regional Economic Strategy as a Regional Hub within which context the two local authorities are working together. The proximity of the Hub to the County border needs to be taken into consideration as both centres influence economically part of East Sussex. The NUTS2 designation focuses in this instance on Kent disadvantaging areas on the fringe of County areas such as Tunbridge Wells. There is a need for consideration in terms of how areas on the fringe of NUTS2 areas are considered and economic growth supported. Surrey County Council s view has always been that counties/ unitary authorities are strategic authorities and should be the default assumption for economic sub-regions. This approach accords with the approach set out in the Government s April 2008 consultation on the Sub National Review of Economic Development and Regeneratio< n (SNR) and Surrey County Council s response to that consultation, which advocated that Surrey is the appropriate economic sub region for our area. We strongly believe that sub regional groupings should be based on the NUTS3 classification (counties and unitary authorities). 5. In parallel, there needs to be further discussion as to how Surrey works on functional issues that cross boundaries, in particular on how the county works across the London Fringe (an area that covers the large proportion of Surrey that borders London, the neighbouring London authorities and Sevenoaks in Kent), the Gatwick Diamond (an area covering parts of east Surrey and west Sussex), and in the Blackwater Valley. While Surrey/ counties remain the default economic sub region, there needs to be a formal recognition that around this boundary, there is, and will always be, a need for cooperation on variable geographies, depending upon the economic challenges. This flexibility is vital. We do not see these arrangements being affected by LABGI. Surrey County Council regularly cooperates with other authorities on day-to-day issues that traverse administrative boundaries. 6. It appears the Government is pressing for Multi-Area Agreements to fully cover the country. We would be gravely concerned if the NUTS2 sub region (Surrey, East and West Sussex, Brighton and Hove) currently proposed for Surrey for the purposes of LABGI was to be the default/ fixed sub region for any Multi-Area Agreement that Surrey might participate in. Surrey has little in common economically with East Sussex and Brighton and Hove; our economy is most similar to that of Berkshire, which, with Surrey, makes up a third of the GVA of the South East region. However, our firm recommendation is that Surrey be classed as a sub region in its own right. Thus we strongly advocate sub regions based on the NUTS3 classification. 7. We have discussed the proposed sub region for Surrey with the other local authorities concerned, as well as with all the counties in the South East region. Like Surrey, they too believe that the proposed NUTS2 grouping is not appropriate, and see counties/ unitary authorities as the default economic sub region. We oppose the move towards sub-regions as a means of distributing funds. We feel that this acts against the aim to keep things predictable and, in fact, will serve to keep a level of unpredictability. Whilst sub-regional working will ensure that more councils will get something, those with good growth will receive less as their funds become diluted across the sub-region. This weakens the link between growth and the incentive, which should remain a fundamental aspect of the scheme. The default option gives the impression that sub-regions will be imposed upon local authorities. The imposition of such boundaries can hinder partnership working rather than help. We believe the default position should be that of individual authorities, with sub-regional partnerships being available only if local authorities choose. There is good partnership working amongst some councils at county and district levels already. The imposition of additional boundaries could undermine this work. As sub-regions, it is possible that less grant payment will be made overall. This is owing to the fact that negative growth does not count towards the scheme, only positive. If local authorities are clustered together and some achieve no growth, this is taken into account and averaged out across the sub-region. By splitting into separate local authority areas, the actual amount of money distributed across the same geographic area could be greater. As a district with good predicted growth we propose splitting into separate authorities will bring greater results in the areas where most growth is achieved. Our preferred options, (in order of preference) are as follows: 1. Suffolk Coastal District Council  NUTS4 boundary. We would prefer to remain independent, ideally. 2. Suffolk  This option is our preferred option if the condition that states we need to be part of a cluster of authorities is imposed. It < is preferable as it is smaller than an East Anglia group which we feel would be too remote. 3. Haven Gateway  We feel that the Haven Gateway reflects a real economic geography but recognise that this is not permitted within the consultation guidelines as not all of the district is in the area and we can only be included in one sub-region. 4. NUTS2 region: East Anglia  We feel this area is too large and unwieldy. It does not reflect a real economic area and would make the management of funds on the ground complex and take away any incentive to deliver economic growth on the part of the billing authority. Our ideal scenario is that the area receiving funds should be the same as the billing authority area in order to keep the strong links between the reward and the incentive to develop the economy. Joining areas together to create sub-regions simply distorts the picture and does not offer an incentive to develop business growth (which is and should remain the main focus of the scheme). So whilst Suffolk is our preferred option in this context, our real desire is to remain as a unique and independent body. The consultation paper seeks views on which sub-region the Council considers itself aligned to. Whilst there is no standard definition of a sub-region the concept seeks to describe an area with a functioning socio-economic geography, Irrespective of local authority boundaries. The Council is currently working with a whole range of different sub-regional partnerships, including the North Staffordshire sub-region (with Stoke-on-Trent and Newcastle under Lyme), the Northern Housing Market (which adds East Staffordshire and Stafford Borough to the North Staffordshire grouping) and the rest of Staffordshire through the Staffordshire Partnership and LAA. The District also has functional linkages with Derbyshire, principally High Peak and Derbyshire Dales. If the point of the LABGI scheme is to promote economic co-operation and development across sub-regional boundaries then the sub-regions should reflect more closely the actual joint-working involved. In most cases this will be at a much more localised level than the proposed NUTS2 level. The Council has concerns over the use of NUT2 regions and argues for a more localised sub-regional arrangement. The District has strong functional economic linkages with the North Staffordshire conurbation (as evidenced by commuting patterns for example) and it is suggested that a sub-region based on the North Staffordshire Regeneration Partnership should be considered. It is recommended that a draft list of proposed sub-regions is published for comment before the government seeks to permanently allocate an authority to a particular sub-region. In response to a request for clarification from CLG: Staff Moorlands' only partners are Stoke City and Newcastle-under-LymeMembers of AGMA (Ten Greater Manchester Local Authorities) who happen to fall into the same NUTS2 areas as those shown at Annex B of the consultation paper. In response to a request for clarification from CLG: Authorities we believe fall into the same sub-region as Stockport are: Bolton Bury Manchester Oldham Rochdale Salford Tameside Trafford Wigan All these authorities and ourselves comprise the Greater Manchester NUTS 2 sub-region.The new scheme is much more focused on sub-regional development rather than individual authorities. A local authority that has a negative growth in NNDR yield would still receive a reward if its sub-region qualified for reward if its sub-region qualified for a reward as a whole. This takes the emphasis away from a Local Authority incentive, which is at the heart of the scheme. Also, by allocating Local Authorities into regional groups, it is implied that those authorities are actively working together to encourage business growth. This may not be reflective of actual circumstances. The Council would, therefore, support a scheme in which local authorities are given the freedom to decide their own groupings to encourage cooperation and partnership working with economic development partners. Various factors may influence this decision including the current working arrangements with Multi Area Agreements. In response to a request for clarification from CLG: We would prefer being grouped into a sub region based on our MAA - so that is Darlington, Hartlepool, Middlesbrough, Redcar and ourselves. There is is a general feeling that our economies are intrinsically linked. The County Council strongly supports the general approach set out in the consultation paper that it is appropriate for economic regeneration to be planned and delivered at a sub regional level. This is because; (a) The management of economic regeneration at the sub regional level is totally consistent with the overall approach of the Local Area Agreement (LAA). This is based on the sub region of Staffordshire and has been in place for the last three years. This has also been re-enforced by the local performance framework, introduced as part of the 2001 Comprehensive Spending review. This approach is working well in Staffordshire, encouraging the building of genuine partnerships at the strategic level to deliver economic regeneration. (b) The sub regional approach is also consistent with the development of the Area Based Grant regime, designed to support the development of LAA priorities, including economic regeneration. The Area Based Grant is managed at a sub regional strategic level. In Staffordshire in 2008/9, the Area Based Grant covers 36 different funding streams totalling 32m. This will increase to about 47m in 2009/10. (c) This approach is also consistent with the Sub National Review of Economic Regeneration published in July 2007. This made a number < of proposals which broadly support a sub regional approach to managing and delivering regeneration. For example, the SNR proposes a duty on upper tier authorities to prepare a Local Economic Assessment, and raises the possibility of the delegation of funding to local authorities and sub regional partnerships. It is also the County Council s view that the appropriate local authorities to work together for the purpose of cooperation on economic development are Staffordshire County Council, the Staffordshire District and Borough Councils and Stoke on Trent City Council. It is not considered appropriate for this sub region to cover Shropshire. The County Council does not, therefore, agree with the proposal set out in the consultation document to use NUTS2 groupings. The reasons for this are that; (a) The economic linkages between Staffordshire and Stoke on Trent are considerable. There are major travel to work movements between Staffordshire and Stoke on Trent, as well as movements of people for shopping, leisure and education. The links between Staffordshire and Shropshire are relatively much lower. (b) There is considerable joint working and joint planning in a number of fields, including economic regeneration between Staffordshire and Stoke on Trent. For example, marketing for inward investment and tourism is organised and delivered jointly by partnerships covering both Staffordshire and Stoke on Trent. Again, links between Staffordshire and Shropshire are relatively weak and undeveloped. Somerset County Council s position is that the administrative County of Somerset should form the defined sub region for our area for the purposes of the new LABGI scheme. We have consulted with our partner District Councils who share this position. We have also consulted with our neighbouring upper tier authority, Dorset County Council, given the proposal in the consultation document that the combined area of Somerset/Dorset/Bournemouth and Poole should form a single sub region for the new scheme. The upper tier authorities believe that Somerset and Bournemouth, Dorset/ Poole should be separated for the new LABGI scheme. There are two reasons for this: " the combined areas of Somerset, Dorset, Bournemouth and Poole are economically very diverse and do not function as a coherent economic sub region. Other than for the eastern parts of Somerset, there are no significant economic inter-relationships between Somerset and Dorset/Bournemouth/Poole. " Somerset County Council understands that Dorset/Bournemouth/Poole are collaborating in a Multi Area Agreement (MAA) and naturally local authorities in that area wish to pursue the links between LABGI and the delivery of the MAA which would be diluted in a shared economic sub region with Somerset.South Gloucestershire normally works formally and informally with the other three members of the former Avon area comprising the West of England sub region i.e. with Bath and North East Somerset, Bristol City and North Somerset. The formal West of England Partnership is in place and covers a range of functions on a sub -regional basis including economic development. The 4 Authorities are one of the areas piloting Multi Area Agreements.%It is proposed that local authorities are grouped by county areas. For Devon, a single grouping is proposed, including the two unitary authorities of Plymouth and Torbay. Grouping on a wider area is seen as beneficial. An alternative grouping could be based on the Plymouth SSCT s travel to work area (that includes the city itself, parts of Caradon District Council, parts of West Devon Borough Council, and the western half of South Hams District Council) where cooperation is discussed through the Plymouth Sub-regional Economic Partnership. Our primary sub-regional partners are: Lincolnshire County Council, Boston Borough Council and South Kesteven District Council with to a lesser extent East Lindsey District Council. However there is also, in reality, a strong economic link between the areas of South Holland District Council and Peterborough Unitary Authority and Fenland and North Norfolk, there is a considerable amount of commuting and business links between these areas, although as these latter authorities are in the Eastern Region and SHDC is in East Midlands actual co-operation between the public sectors tends to be limited to specific projects otherwise consisting mainly of regular meetings and an exchange of information. A logical sub-regional grouping for South Somerset would be with the other Somerset authorities and Dorset, West Dorset given Yeovil s very close proximity to the Dorset border. There are also som< e economic links with North Dorset, Salisbury and East Devon.South Tyneside would consider itself to be part of Tyne and Wear for the purposes of economic development. Partners within Tyne and Wear consider the boundaries of the economic city-region to be drawn more broadly (to include elements of Northumberland and County Durham.) The Tyne and Wear city-region partnership has developed a Multi-Area Agreement, based on Tyne and Wear as an economic area. We appreciate that it would be very difficult to consider The Tyne and Wear city region boundary as suitable for LAGBI (given that it would create an area of the Tyne and Wear city region, and 2 much smaller residual areas in Northumberland and Durham.) Similarly it would complicate calculation and distribution formulas to the new unitary Durham and Northumberland authorities, given the relative vaugery of the city-region boundaries, compared to existing sub-regional boundaries. As such, while the Council would suggest that the proposed sub-regional area for ourselves (Tyne and Wear and Northumberland) means the inclusion of some geographical areas in Northumberland which don t have economic impact on Tyne and Wear, we believe the proposed NUTS 2 area represents the best possible compromise, and does not disadvantage South Tyneside.UIt would be Southwark s preference for LABGI to be distributed on a borough by borough basis, each being its own sub-region, as we feel this is a much better reward for the activities undertaken at a borough level and in this respect it would act as a direct incentive for each local authority. If sub-regional distribution is preferred then Southwark would support a Central London grouping (Camden, City of London, Islington, Kensington and Chelsea, Southwark and Westminster), this would reflect the redevelopment in the area and share the reward among the authorities generating the increasesLABGI funding has been very useful and we are pleased that you propose to retain it. We are not so pleased with your proposed new arrangements, however. Previously LABGI was awarded directly to local authorities. This worked well and we can see no reason for it to be changed. It means there is a strong and direct link between economic performance and reward, which is diluted if the reward is spread across a larger area. Most economic development projects are local, especially regeneration projects, and LAGBI provided a crucial source of funding for these. If the Government insists upon allocating LABGI on a sub-regional basis, we regard St Edmundsbury as being in the Great Cambridge sub-region, as well as the Cambridgeshire local authorities and our neighbour in West Suffolk, Forest Heath. St Edmundsbury District is in West Suffolk but its economy is greatly influenced by its proximity to Cambridge. It is a member of the Greater Cambridge partnership and is identified as being within the Greater Cambridge engine of growth in EEDA s regional economic strategy. For the purpose of co-operation in economic development, therefore, St Edmundsbury regards itself as being in the Greater Cambridge sub-region. Its neighbouring authority in West Suffolk, Forest Heath, shares this view, and the authorities in Cambridgeshire have indicated that they could welcome the inclusion of West Suffolk within the Greater Cambridge area.{The Council collaborates and works jointly with a range of other authorities and bodies to deliver economic development. It has particularly strong partnerships in the Birmingham, Coventry and Black Country City Region, with Coventry and Warwickshire, and bilaterally with Birmingham. Particular arrangements and partnership working depend on the issues to be addressed, with examples being the City Region City Strategy Pathfinder and emerging MAA, a Birmingham and Solihull Employment and Skills Board, and the Coventry, Solihull & Warwickshire Partnership  a longstanding and successful economic development partnership. Solihull s Cabinet has recently considered Solihull s approach to sub-regional working and agreed that all these relationships with the City Region, Coventry< , Solihull and Warwickshire and Birmingham should be maintained and developed, but with Coventry, Solihull, Warwickshire a focus for pursuing Solihull s economic growth agenda. Accordingly, the Council s view is that it should be grouped in the same sub-region as Coventry and Warwickshire for the purposes of the LABGI scheme: - " There are strong partnership arrangements in place, with the Coventry, Solihull, Warwickshire Partnership. Economic planning and investment strategies have been at the heart of the work of this partnership for many years. " The CSW sub-region is a key growth corridor recognised in regional and national spatial strategies. " There is an established and rapidly growing Coventry, Solihull & Warwickshire High Technology Corridor, formally recognised in the Regional Spatial Strategy and West Midlands Economic Strategy, with key economic development assets including Coventry and Warwick universities, and partners are seeking the development of the same technology sectors for sustainable economic development in the future. " Travel to work patterns show strong economic inter-relationships, particularly between Coventry and Warwickshire. In response to a request for clarification from CLG: Solihull's view is that it should be grouped in the same sub-region as Coventry and Warwickshire (County and Districts) for the purposes of the LABGI schemeWe strongly believe that all of the London Boroughs should be defined as being in the same sub-region for the purposes of cooperative economic development and therefore AGREE that London should be treated as a single sub-region for the purposes of the scheme. London is the primary centre of economic activity and business growth within the United Kingdom and in the next few years will see significant development and economic benefit arising from the delivery of the 2012 London Olympic Games. As all London Council Tax payers are being required to contribute over a ten-year period to the funding of the 2012 Games it is appropriate that they receive an equal share of the economic benefit that will be derived. It is important to note that the Government has already determined London as a single sub-region for the purposes of raising funding to support economic development through the introduction of the Supplementary Business Rates Scheme (SRB), with the power to levy such a charge assigned to the Greater London Authority, and not at an individual authority level. For these reasons Redbridge strongly supports the definition of London as a single sub-region for the purposes of the LABGI distribution scheme.9Redditch Borough Council considers itself to be part of the Worcestershire sub-region. We are not part of any MAA but have a strong LAA partnership (the Worcestershire Partnership) and actively pursue co-operation in economic development. Economic development activities in Herefordshire and Warwickshire do not impact on Redditch any more than those in Birmingham; whereas in Worcestershire we have joint initiatives and cross-border working with the County Council and the other districts in the county (ie Bromsgrove, Malvern, Worcester, Wychavon and Wyre Forest).The sub region of Manchester is an already established group which Rochdale Council is a member. The Manchester sub region group shares a boarder with Rochdale, has already developed good working relationships and recognises the importance of cooperation between the Members. The ten Greater Manchester Local Authorities are in the same NUTS2 area as shown at Annex B of the consultation paper.Thames Gateway South Essex comprising Southend, Thurrock, Basildon, Castle Point and Rochford. This reflects the focus on economic regeneration in this subregion. We feel that being part of the Essex group would dilute the focus of the Thames Gateway South Essex, part of the largest regeneration initiative in Europe, and one which Government has Identified as a key priority for the Country.VRotherham would be content to form part of the South Yorkshire sub-region with Barnsley, Doncaster and Sheffield, as the districts have an established history of working together at this level on a number of issues and this reflects current patterns of development. For example, a recent CURS report highlighted the fact that Rotherham and Sheffield operate as a single economy, which has enjoyed transformational growth, above both regional and national rates in recent years. These linkages are through direct business interactions, strong sectoral complementarities and a shared labour market.8(Supports proposal made by Basingstoke & Deane) Response from Basingstoke & Deane: Economically Hampshire is split into 2 parts, north and south, with the Partnership for Urban South Hampshire in the south of the county. Basingstoke and Deane is situated in the north of the borough and our natural economic partners are the districts of Test Valley, Hart and Rushmoor. The north Hampshire authorities are at the early stages of investigation into an MAA. Basingstoke and Deane Borough Council believes that the sub-regional grouping for LABGI should reflect thisThe Council believes that the proposed scheme fits with our commitment for greater collaboration between the Greater Manchester Authorities. However, if the Government is also committed to sub-regional cooperation it must provide greater incentives and support to sub-regional based economic activities. The Council agrees that the most logical grouping would be with the other Greater Manchester Authorities in line with the areas defined by NUTS2. Sandwell already works in close partnership with its three Black Country neighbours, Walsall, Wolverhampton and Dudley through the Black Country Consortium. However, Sandwell s geographical position results in a high level of engagement between its residents and the neighbouring City of Birmingham. The Borough therefore also has significant interest in any advantages that may be delivered by collaborative engagement at City Region level.Response from Shropshire County Council: The consultation proposes linking Shropshire with Staffordshire and Telford & Wrekin. From an Economic Development point of view < this grouping would not reflect a  real economic area . In terms of  economic make-up , a partnership with Herefordshire & Worcestershire would be more representative of a real economic area. The Regional Development Agency has taken a similar view in developing its own economic delivery mechanisms i.e. Advantage West Midlands considered a rural regeneration zone based upon the three counties of Shropshire, Herefordshire and Worcestershire to make an appropriate sub-regional grouping.Preston City Council regards the Central Lancashire grouping of Preston, South Ribble and Chorley local authorities as being in the same sub-region for the purposes of co-operation in economic development. An alternative wider grouping would be the Mid Lancashire local authorities which includes Lancaster and West Lancashire in addition to Preston, South Ribble and Chorley. In response to a request for clarification from CLG: In response to your query regarding the alternative wider grouping, I would like to confirm that this response is correct. The reasons for responding in this way are outlined below. The Mid Lancashire grouping is considered to be the best way of dealing with economic footprints within Lancashire. Wyre is part of the Fylde Coast economic area, centred around Blackpool, and Ribble Valley is part of the East Lancashire economic area. Both are part of the MAAs for those respective areas. The three Central Lancashire authorities (Preston, South Ribble and Chorley) are both contiguous and part of the same functional economic area. West Lancashire has contiguity with that area, and although Lancaster is not immediately contiguous, it has in common with the other 4 boroughs its location on the North / South growth axis. In addition the Mid Lancashire area includes all of the three universities in Lancashire (UCLAN  Preston; Lancaster  Lancaster; and Edge Hill  West Lancashire). The area also has three of the five Gateways in Lancashire (Preston  central point of arrival and link for East / West transport); Lancaster to Cumbria; West Lancashire to Merseyside). These aspects have been recognised in the Central Lancashire City Regional Development Programme. There are therefore valid reasons for linking together the Central Lancashire FEA with those of Lancaster and West Lancashire, both in policy and economic terms, and also which reflect the exclusion of areas from the existing MAAs. It should be noted that the Mid Lancashire authorities are currently working with Lancashire County Council to establish a  quasi-MAA for the area (only one upper tier authority in the area) and establishing a Mid Lancashire Support Unit, using RIEP monies.The proposal to focus the calculation of LABGI grants on sub-regions appears logical and we welcome the Government s proposal to afford local authorities opportunity to determine sub-regional geographies. We appreciate that the Government is seeking to strengthen the resourcing of Multi-Area Agreements (MAA) partnerships, where they exist, by offering scope for MAA areas to become sub-regions in a LABGI context. However, in the absence of MAAs or other inclusive voluntary arrangements between relevant district, county and unitary authorities, we would suggest that Local Area Agreement (LAA) areas should be the default sub-regions for LABGI. This would, we believe, strengthen local LAA delivery and performance and be entirely consistent with the Review of Sub National Economic Development and Regeneration (SNR) proposals. To reinforce this point, it is worth highlighting that, in the East Midlands, the East Midlands Development Agency (emda), has taken the welcome step of amending its sub-regional delivery arrangements to align with LAAs and MAAs, where they exist. In response to a request for clarification from CLG: Nottinghamshire as at present 2 EMDA sub regions, but we have recently agreed with EMDA to work towards just one sub region in the county based on the LAA for Nottinghamshire which includes all of the County with the exception of Nottingham City. We are also looking at the possibili< ty of a MAA which would include the County and the City. Hope this answers your question. rEvidence from the LGA and others clearly shows that the county of Oxfordshire is a functional economic region in its own right. We feel strongly that this should be recognised by the new LABGI scheme and that Oxfordshire should be regarded as a sub-region in its own right. Local Authorities in Oxfordshire are: " Oxfordshire County Council " Cherwell District Council " Oxford City Council " South Oxfordshire District Council " Vale of White Horse District Council " West Oxfordshire District Council It therefore follows that we do not support the proposal to include Oxfordshire within a wider sub-region including Buckinghamshire, Milton Keynes and the unitary authorities in the historic county of Berkshire. This area covers several sub-regional economic areas and we are very concerned at the proposal that they should be joined for the purposes of LABGI distribution.pIdeally, we would suggest that a local authority grouping based on the functional South East Dorset sub-regional economic area covered by the Unitary Authorities of Poole and Bournemouth, together with the District Councils of Christchurch and East Dorset, would be the most appropriate grouping option. Alternatively, a sub-regional grouping based on the area covered by Dorset County Council and the Unitary Authorities of Bournemouth and Poole would be acceptable. It should be noted that in July 2008, a formal Multi-Area Agreement was signed between these authorities. From a Poole perspective, it is considered that should a sub-regional grouping based on the functional economic area not be acceptable, a grouping based on the larger Dorset sub-regional area would be more appropriate than the proposed sub-regional grouping based on the Counties of Dorset and Somerset.Portsmouth City Council is part of the Partnership for Urban South Hampshire (which brings together 11 councils along the south coast of Hampshire) and is a signatory to the South Hampshire Multi Area Agreement, which is looking to promote economic development in the PUSH area. As such we regard other authorities in PUSH as being in the same sub-region for the purposes of co-operation in economic development. The Push Authorities: Hampshire County Council, the unitary authorities of Portsmouth City Councils and Southampton City Council and the district councils of Eastleigh, Fareham, Gosport, Havant, Test Valley (part), East Hampshire (part), New Forest (part) and Winchester City Council (part). In 2006 Local Authority partners collaborated to prepare the case for greater joint working across the Greater Nottingham conurbation and how this could lead to greater partnership working with National Government. The resulting document,  Showing the Way and its ambitious plans regarding economic, social and physical activities, were presented to the Secretary of State for Communities and Local Government and marked a significant milestone in the development of serious and effective engagement and collaboration at the City Conurbation level. It demonstrated clearly that when referring to and considering  Nottingham in economic, social and physical terms, it was the Greater Nottingham, the City Conurbation that made absolute sense. The local authorities that make up the Greater Nottingham area are:- Broxtowe Borough Council Gedling Borough Council Nottingham City Council and Rushcliffe Borough Council. Ashfield District Council  specifically the 4 wards that make up Hucknall town. The City of Nottingham provides most of the jobs for the people who live in the surrounding areas, such that the creation of jobs and wealth in the City means the creation of jobs and wealth for the whole conurbation. The Boroughs and Districts covering the City Conurbation area have a key role in contributing to the housing, environmental and social conditions which make the City Conurbation a good place to live and which underpin Nottingham s drive for growth and prosperity. There is a truly symbiotic relationship between the City of Nottingham and the surrounding Boroughs and Districts, emphasising that the Greater Nottingham area  the City Conurbation  should be recognised as a functional economic area within the terms of the SNR. We recognise that this consultation paper does not wish to see any districts divided between sub-regions. To meet that criterion would mean that the Hucknall part of the Ashfield District would need to be subsumed into a different area than the City Conurbation. Alternative Option (1) Our preferred option as outlined above enjoys far more support from Nottingham City Council than any other option. We have, however, identified two other options that rank much lower in our priorities but that at least provide CLG and the Treasury with alternatives. Nottingham  Derby Economic Corridor The relationship between Nottingham<  and Derby is an unusually complex and interdependent one. They are located within 14 miles of each other and the main infrastructure route west out of Nottingham towards Derby, the A52, and the surrounding area form an economic corridor. Both Cities have strong identities and common and complementary strengths. This corridor and the two Cities represent a level of geography which is increasingly seen as one business location by businesses operating in the knowledge economy in terms of their site locations and catchment over which they draw their factors of production (workforce, supply chains and business networks). Nottingham s core city vision (to accelerate its economic repositioning to create a competitive city with an economy based on science and technology), will be greatly enhanced by the success of Derby and the economic corridor between the two Cities. This will build on Nottingham s designation as a core and science city and will complement the high value engineering and manufacturing element of Derby s economy. A substantial amount of development in Nottingham is towards the western side of the City which is towards Derby. The Local Authorities involved will be Nottingham City, Derby City and the Borough of Erewash. The latter is a strong catchment area for both Cities, especially in terms of workforce and the Borough is also included in the work around land use and housing supply. Alternative Option (2) NUTS2 The proposal suggests one methodology for selecting sub-regions through the NUTS2 categorisation used by the European Union. All the Unitary Authorities and Districts and Borough Authorities that would be covered under the preferred option and alternative option 1 would fall into either the Nottinghamshire or the Derbyshire NUTS2 categorisation. This would be our least preferred option as, particularly in the north of Nottinghamshire and Derbyshire, the communities, economic activity, including supply chains and travel to work patterns, tend to link to South Yorkshire and specifically Sheffield. As well as being geographically close there are strong ties from the former coal mining industry when North Nottinghamshire and North Derbyshire were part of the South Yorkshire coalfield, as designated by British Coal. In terms of MAAs  discussions are ongoing with partners, including the Government Office for the East Midlands, but agreements have not been signed as yet. Response from Northumberland County Council: The County Council is active in support of the sub-regional partnership for Northumberland which is one of four such sub-regions within the North East of England. The sub-regions work within the framework of the Regional Economic Strategy and Regional Spatial Strategies, which emphasise the importance of the two City Regions within the North East. In this context, the majority of Northumberland is considered to be within the Tyne & Wear City Region and the Council s representatives play an active part in the joint oversight and programming activities for the City Region, including Multi-Area Agreement arrangements. The City Region for Tyne & Wear and Northumberland is within the NUTS2 area. Whilst the sub-region comprises six District Council areas, these Councils will be combined with the County Council in a new unitary authority, for all of the sub-region, from April 2009. The local authorities which form part of the Greater Norwich Development Partnership are Norwich City Council, Broadland District Council, South Norfolk District Council and Norfolk County Council. These authorities are currently collaborating to develop an economic development strategy for Greater Norwich. However it should be recognised that this strategy will have an urban focus based on Norwich City and adjacent parts of Broadland and South Norfolk and a rural focus consisting of the remaining parts of the authorities- to address the more specific needs of market towns and villages. The boundaries do not reflect the economic geography of Greater Norwich in terms of economic development.We strongly believe that the current sub-region proposal is not consistent with other government agenda s (i.e. the growth agenda) which has placed Northamptonshire at the centre of rapid growth within the MKSM region. We believe that in order to reflect the fact that Northamptonshire has been designated one of the major growth regions we should be placed in a separate sub< -region with the lower tier authorities within Northamptonshire. This would, in the true spirit of the scheme, ensure that the benefits created by the extra anticipated growth within Northamptonshire would stay within the region and not be spread across regions who contribute less to the overall increase in business growth. Indeed Northamptonshire is identified as a sub-region in its own right in the current Regional Spatial Strategy for the East Midlands. Moreover it would not be fair for Northamptonshire to be located in a sub-region with non-growth areas. The principle of devolving funding to the Northamptonshire sub-region is also entirely consistent with the rationale and conclusions of the government s sub-national review of economic development and regeneration and its implementation which highlights the importance of upper tier authorities and their sub-regions. Northamptonshire is also served by one single economic development company (Northamptonshire Enterprise Ltd) which works closely with the County, Borough and District councils to promote economic development, growth and job creation. No, we feel strongly that the current sub-region that Northamptonshire is part of does not share the rewards on a fair basis. As such the use of the current proposed sub-region is unacceptable and we feel that as this is scheme is based upon an incentive of business growth it would be unjust that the other authorities within the current NUTS2 sub-region should benefit from the growth both historic and anticipated of Northamptonshire just because they have a larger proportion of population. Therefore we would strongly oppose any sub-region that allowed other authorities to benefit from the work done by ourselves and our lower tier authorities.  Sub regional cooperation has existed in Norfolk since 1997. The Shaping Norfolk Future (SNF) sub regional partnership was formed to bring together the private, public and voluntary sectors to work together to improve the performance of the Norfolk economy. The local authorities involved in (SNF) are all of the authorities within the county boundary. They include Gt Yarmouth Borough Council, Norwich City Council, South Norfolk Council, North Norfolk Council, Breckalnd Council, Broadland Council, Kings Lynn and West Norfolk Borough Council and Norfolk County Council. This partnership has proved to be successful, bringing together more than 300 businesses, organisations and agencies which are committed to working together and sharing resources to deliver activity essential for developing a successful economy. The Shaping Norfolk s Future model has also been trialled at local district level alongside the district Local Strategic Partnership (LSP) and the associated Local Area Partnerships (LAPs). This has led to better local understanding of how districts can contribute towards the sub regional and regional performance agenda. The Council would wish to see a sub region approach that is based on a  city region geography with the core area being the Tyne and Wear authorities of Gateshead, Newcastle, North Tyneside, South Tyneside and Sunderland. The proposed use of a NUTS2 geographical area covering Tyne and Wear together with Northumberland would also be supported as this also provides a reasonable  fit with the functional economic area of Tyne and Wear. Comment from introduction to response: It is also felt that in the context of the Tyne and Wear area, that a sub regional approach is appropriate as this fits with our economically functional geography and the agreement between the relevant Councils to participate in City Region level working in order to improve economic outcomes and performance. This commitment to City Region co-operation is demonstrated through the agreement of a Tyne and Wear Multi Area Agreement with Government in July 2008.`For North Yorkshire we would see the 7 District/ Borough Authorities as part of the same Sub Region based on the Geographic Programmes created by the Local RDA for North Yorkshire. Further co-operation could be potentially forthcoming with the adjacent Unitary of the City Of York which creates the NUTS < 2 area of North Yorkshire. Co-operation in the field of economic development with the City of York is facilitated through the North Yorkshire Development Board and the North Yorkshire Partnership Executive who co-ordinate the input into both LAA2 in terms of the  Economy Priority within the document We are part of the Milton Keynes South Midlands growth sub region and regard ourselves as part of that sub region rather than the NUTS2 region. We can see the logic of using NUTS2 regions but their use would ignore the growth regions of Milton Keynes South Midlands, the Thames Gateway and Ashford and as such could disadvantage the authorities in these growth regions. Sam Davies confirmed in e-mail of 26 Nov 08 that their preferred sub-region would consist of: Aylesbury Vale, Bedford, Mid Bedfordshire, Luton, South Bedfordshire, Milton Keynes, East Northamptonshire, Corby, Kettering, Wellingborough, Daventry, Northampton, South NorthamptonshireIn line with having similar historical economic development issues and levels of deprivation we consider Ashfield & Bolsover District Councils being in the same sub region. This is supported by the joint work undertaken over the last two years through the partnership that was formed to secure  Local Enterprise Growth Initiative funding. This would appear to meet the criteria set out in the paper. The proposed sub region applicable to Mansfield in the paper is in our opinion too large and diverse to have any relevance as regards cooperation over economic development issues. The smaller sub region of Nottingham shire may be more appropriate although again are diverse issues that may limit cooperation particularly if Nottingham City UA is included. While the Government proposes that London as a whole be treated as the functional economic area for the purposes of co-operation in economic development, we consider that the scale of this arrangement would be too broad to allow for effective and practical partnerships initiated by local authorities. Furthermore, there are already economic development agencies working at the regional level. The paucity of real, practical co-operative economic development initiatives between authorities at the sub-regional level is largely because the sub-regions as currently configured incorporate the  wrong groupings. Although the South London boroughs may have interests (and political outlooks) in common, the limited  adjacentness of the current South London grouping (strung out from Richmond to Bromley) limits the range and extent of joint solutions to local economic problems, and exacerbates the logistical difficulties involved in organising and implementing joint action. The grouping which the Merton Council would support as offering practical and fruitful opportunities for economic development co-operation would include : Lambeth, Wandsworth, Merton, Sutton, Croydon and Kingston. If co-operation is to take priority over competition, this South West segment grouping is considered preferable because it represents a genuine economic entity bound together by transport links, travel to work patterns and complementary opportunities for action and investment.Sub-region for Middlesbrough Council should include; Middlesbrough Council, Stockton-on-Tees Council, Hartlepool Council, Redcar and Cleveland and Darlington Council. All the local authorities are part of Tees Valley Multi Area Agreement. All but Darlington Council are contiguous authorities to Middlesbrough Council, reflecting economic areas and are not expected to change in the foreseeable future. Middlesbrough Council is a unitary authority, not a district authority. Therefore, we disagree with the NUTS2 category i.e. to include Tees Valley and Durham. The Government has not provided information on rules on qualifying sub-regionsIn Norfolk s case the NUTS 3 grouping, based on Norfolk County boundary, and reflecting the area used for Formula Grant calculation is the most practical and realistic grouping. The County Council welcomes the consultation proposal that local authorities themselves should form sub-regional groupings. The proposal to use NUTS 2 classifications is, however, flawed for many reasons; the most obvious being that in many cases they do not fulfil the Government s proposal that sub-regions should reflect  real economic areas . We would argue that in cases where sub-regional groupings would not be in the best interests of an area, upper-tier authorities should function as default sub-regions for the purpose of the LABGI scheme. North Devon Council would consider that the most relevant sub are in fact slightly smaller than the NUTS2 sub region, and would be based on a Functional Economic Area and travel to work patterns, rather than the shire county boundary. Ideally the area would comprise Torridge District and Mid Devon District, rather than the NUTS2 sub region which would be identified a< s the full county of Devon. However, it is acknowledged that a great deal of cooperation on economic issues already exists with all the local authorities in the Devon NUTS 2 sub region, and it would be accepted that there may be greater efficiencies and existing mechanisms through using NUTS2 sub regions rather than establishing new, smaller Functional Economic Areas based sub regions. If the larger sub region is the preferred option this should include Plymouth and Torbay for the county of Devon as both are important economically influential areas. Manchester city region has a long history of strong civic leadership and collaboration, which is widely regarded as being a major contributor to its economic success. The Association of Greater Manchester Authorities (AGMA) was established in 1986 and acts as the voice of the ten local authorities (LIST), (working in partnership with a wide range of private, public and third sector organisations within the city region. At the heart of city region, the city of Manchester is the economic engine of the both the region and the sub region with a concentration of people and business activity without parallel in the north of England. Manchester s economy has been growing strongly for the past ten years, and while current conditions are challenging, the latest projections confirm that higher than average economic and population growth will be a continuing feature of the city s economy in the medium and longer term which in turn will drive growth in the sub region and beyond. Within the city region we have a track record of collective strategic accountability for delivering major projects and initiatives - for example our Multi-Area Agreement signed this summer, Metrolink, the new Waste Management Contract (the largest and most complex of its kind in Western Europe), and the expansion of Manchester Airport (owned by the 10 authorities). We have a culture in which the principle of being jointly and severally liable for initiatives where we work together is understood. Whilst we therefore place great importance on working together at a regional level to promote economic growth, there is a risk that the scheme, as proposed with the allocation on a per capita basis could actually cause conflict between the local authorities. If allocation between the sub-regional authorities is to be prescribed, a fairer system would be business growth or business yield. The per capita allocation penalises the growth generating authority by diluting the benefit gained and distributing it amongst the other authorities in that sub region. For example over the previous LABGI period Manchester saw a 43% increase in business growth but only 11% in its population. It also seems perverse to have a scheme called a  Local Authority Business Growth Incentive and not to distribute the reward based on either growth or yield. The LAA reward grant is distributed on the basis of performance against economic indicators and not on a per capita basis. Similarly the Housing Planning Delivery grant is distributed on the basis of increased housing stock. Manchester has a key role in driving the city region economy. Much of the investment to support economic growth is provided and led from Manchester. This important role and level of reward would not be adequately reflected in the LABGI proposals as put forward In response to a request for clarification from CLG:: Manchester places great importance on working together at a regional level to promote economic growth. I can confirm that the list of authorities corresponds with those in the consultation. However MCC feel that it is not necessary to impose collaborative working via LABGI. We would therefore prefer to be regarded independently for LABGI purposes. In addition to Leicester City Council the other local authorities who are party to the Leicester and Leicestershire Sub- Region Multi Area Agreement are: Leicestershire County Council Blaby District Council Charnwood Borough Council Harborough District Council Hinckley & Bosworth Borough Council Melton Borough Council North west Leicestershire District Council Oadby & Wigston Borough Council #The District Council accepts that NUTS2 clusters should be used for distribution of LABGI funding in East Sussex, in our case joining East Sussex with Brighton and Hove, West Sussex and Surrey, although this sub-regional grouping may not be appropriate for all economic development purposes.hWe would regard the authorities of Merseyside as being in the same region as ourselves for the purposes of cooperation in economic development, specifically, Knowsley MBC, St Helens MBC, Sefton MBC, Wirral MBC and Halton BC. These authorities form the basis of our sub-regional governance arrangements and the Multi Area Agreement for the Liverpool City RegionYSub National Review argues the case for local authorities to work together around functional economic geographical areas. An area includin< g Ashford, Swale, Medway and Tonbridge and Malling would be a closer fit for Maidstone than the NUTS2 area. However no formal working relationship exists between these authorities presently so where there is an absence of an agreement, legislation to create a Economic Improvement Board, a MAA or even Growth Area partnership e.g. PUSH , Maidstone argues that as a Growth Point, government should consider us as a single authority area for the purposes of LAGBI.There are varying definitions of the  sub-region being proposed in different policy/strategic documents which potentially confuse and influence local authority activities. It is suggested that if one definition is to be used then it should be the same throughout government arrangements e.g. the Sub-National Review of Economic Development and Regeneration and Local Area Agreements. Within these proposals Worcestershire, has been identified as a Sub-Region and should therefore be considered as such for the purposes of managing the LABGI funds. The Malvern Hills District Council as part of Worcestershire cooperates with several Local Authorities within the context of Economic Development depending on the common projects/priorities. We already work with partners outside the sub-region where there are similarities and we would not want to force similarities on the basis of the NUTS2 groupings. For example Birmingham and Worcestershire are different yet where there are common themes both authorities work with each other as partners. Examples include the Central Technology Belt. If Worcestershire cannot be viewed as a separate sub-region then we are content to be grouped with Warwickshire and Herefordshire. Leeds sits at the heart of a cohesive city region made up of the ten local authority districts of Barnsley, Bradford, Calderdale, Craven, Harrogate, Leeds, Selby, Wakefield and York. These authorities, together with North Yorkshire County Council have worked together over a number of years, cooperating to put in place a Comprehensive Regional Development programme in 2006, contributing to the Regional Economic Strategy for 2006-2015, and developing a pilot Multi-Area Agreement (MMA) signed off in the summer of 2008. Our MMA recognises that our shared economic priorities such as tackling high level skills gaps and reducing transport congestion are best delivered collectively by cutting across traditional administrative, partnership and functional boundaries. Whilst we appreciate the invitation to propose alternative sub-regional groupings, we find it disappointing that the preferred sub-regional geography exemplified in the consultation is based upon the NUTS classification rather than upon city regions. We see no strong argument for using the NUTS 2 classification for areas outside London. The arguments for adopting the NUTS 3 classification, which would place Leeds in a  region by itself, seem equally strong and would remove some of the anomalies in NUTS 2 that lump authorities together into artificial  sub-regions such as  Leicestershire, Rutland and Northamptonshire , which do not reflect real-world linkages. Another alternative could be to dispense with the regional approach altogether and to treat districts as individual economic entities for the purposes of the new scheme as was the case under the old scheme. However, this would markedly increase variations in rewards between authorities. The problem with all of these alternatives is that because the national totals are limited any alternative groupings, including a geography based on city regions, would necessarily create  winners and  losers , and risk pitting authorities against one another. Having said that, we believe it is vital that the groupings adopted properly reflect the ways that local authorities are working together to achieve shared economic objectives and to improve the lives of their citizens. In this area, these strategic aims are being achieved through the MAA agreed by the Leeds City Region members. We believe, therefore, that the LABGI grouping for this area should reflect the City Region membership, but with one caveat. Barnsley is a member of two city regions: Leeds and Sheffield. In our view, Barnsley s economic and social linkages are equally strong to each region. Whilst many of our economic priorities are < region-wide and intertwined, in the long-term Barnsley s economic development aspirations may be more closely aligned with the other South Yorkshire authorities, making it more appropriate for Barnsley to be included in the Sheffield City Region for LABGI purposes. In response to a request for clarification from CLG: The MAA does indeed include Kirklees.Bristol is working increasingly closely with the adjoining unitary authorities on land use planning, transportation, economic development, housing and waste management. ۃ However it is difficult to understand how the use of arguably, obscure sub-regions, however defined, would enable individual local authorities to accrue the benefits that result from their policies which successfully stimulate economic growth, and which would provide clear incentives and produce outcomes that are transparent and simple to understand and predict. Accountability to the local tax payer would be even less clear. In reality, unless member authorities of any defined sub-region are working together in equal partnership to stimulate economic growth for that region then any distribution mechanism using that region would not be fair or equitable and would not provide clear incentives. The reward (per capita) for a high growth authority would be the same as a low growth or negative growth authority within the same sub region. There would seem to be little incentive for authorities with relatively small yields to invest in stimulating economic growth as their impact on the overall award would be negligible in terms of the allowance per capita within sub-region. ۃ For these reasons Bristol considers that the distributed of any sums under the LABGI scheme should be on the basis of the growth in individual Local Authority areas and not on the proposed basis.tThe London Borough of Bromley is strongly in support of the Department of Communities and Local Government (CLG) view that London should be regarded as a single region, encompassing all London authorities. A single economic area is the most appropriate grouping for Bromley and London as a whole. The performance of the economy in Central London is strongly driven by residents of Outer London boroughs and the cost of services to those people is met by their resident borough, not their place of work. There is no obvious alternative that takes into account the inter-dependency of the different parts of the London economy.We concur that the authorities defined in NUTS 2 - Herefordshire, Worcestershire and Warwickshire - are appropriate. Within the Worcestershire County we regard the adjacent districts of Redditch and Wyre Forest as being the most relevant within an Economic Development context. In response to a request for clarification from CLG: Bromsgrove, Redditch and Wyre Forest is the preferred option. \Broxtowe has been working in the Greater Nottingham Partnership for the purposes of economic development along with Nottingham City Council, Rushcliffe District Council and Gedling Borough Council. To move towards seeking to promote economic development on the basis of other sub-regions seems to be at odds with government policy on city regions.nWe do not feel it would be appropriate to group with other local authorities in the sub-region for the purposes of this scheme and propose that Buckinghamshire (excluding Milton Keynes), is treated as a unit in its own right. County authorities working in close collaboration with their districts and boroughs in existing LAA areas provide the obvious  sub-regional arrangement for delivery of LABGI. Please also refer to the collective response submitted via the South East County Leaders (SECL) group. We understand that Oxfordshire and Berkshire would also like to be considered as their own discreet  sub-regions . 7Cambridgeshire County Council and its constituent district councils consider that the county forms an appropriate sub-region for ED co-operation purposes. This is the core area covered by the sub-regional economic partnership (Greater Cambridge Partnership - GCP) and the growth area LDV (Cambridgeshire Horizons). GCP and the area covered by the Greater Cambridge engine of growth in the RES include parts of adjacent districts in Suffolk, Essex and Herts and it may be appropriate to extend the area to include some of these districts which look to Cambridge for employment, shopping and cultural purposes. St Edmundsbury BC and Forest Heath DC in Suffolk have indicated their preference to be included in a Greater Cambridge sub-region incorporating the five Cambridgeshire districts and St Edmundsbury and Forest Heath.Camden questions the practicality of obtaining a coherent view in the time allowed for receipt of responses and for London boroughs questions 1 and 2 are posed in an incorrect order. Nevertheless we have had discussions with the other central London boroughs about a London sub-regional structure. Camden has concluded that the principle aim of the LABGI scheme, that of promoting economic growth would for London be best served by a London specific sub-regional structure and that there should be central London sub-region. We also believe that more cross borough working will occur in a structure that groups boroughs into a number of sub-regions.^Although the Council is in agreement and is a lead player in partnership arrangements it fundamentally disagrees with the use of sub  regions as a methodology for determining and distributing Business Growth resources. If LABGI is to < stand alone, in the short term, from other performance frameworks as indicated in the consultation note then LABGI should reflect individual performance, based upon sub regional targets rather than sub regional performance Subject to the above argument being disregarded the Council believes that existing partnerships should be the key factor in determination sub  regions. Economic Development represents only one aspect of local service provision and it is essential that a joined up approach is adopted for the provision of all services within the community. This is currently provided by the Staffordshire Local Area Agreement and consequently the advantages of Business Growth being one of the target areas agreed as part of the LAA forms a logical method for the ongoing provision of a mainstreamed LABGI reward scheme. More pertinent to the question asked a sub group of Staffordshire Authorities exists specifically for economic development and regeneration and includes six of the eight districts of Staffordshire notably Cannock Chase, East Staffordshire, Lichfield, South Staffordshire, Stafford and Tamworth. The partnership brings together the private sector, local authorities, the education sector, business support agencies and the voluntary sector to promote the economic regeneration of the Southern Staffordshire area and represents the logical sub region for this authority. Thames Gateway South East Authorities In response to a request for clarification from CLG: The authorities are Basildon District Council, Thurrock Council (Unitary), Southend-on-Sea Borough Council (Unitary), Castle Point Borough Council and Rochford District Council.In the short term Cheshire and Warrington would support the proposed Cheshire NUTS 2 grouping including Cheshire East, Cheshire West and Chester, Warrington and Halton. However, in the longer term we would wish to see Halton's economic position calculated independently of Warrington, Cheshire East, Cheshire West and Chester as its economy is more consistent with the economy of the emerging Liverpool City RegionCheshire East, Cheshire West and Chester and Warrington, we would not want to use our NUTS 2 designated sub-region as this includes Halton. Additional response received: In the short term we would support a grouping including Cheshire East, Cheshire West and Chester, Warrington and Halton. In the longer term we would wish to see Halton's economic position calculated independently of Warrington, Cheshire East and Cheshire West and Chester as its economy is more consistent with the economy of the emerging Liverpool City Region.In order to achieve the desired reward/incentive objectives of the scheme the groupings should not be so large as to smooth out the effects. A single authority or county region is the Council's preferred option. In response to a request for clarification from CLG: Our preferred option is for regions to be based on single authority areas i.e. districts & unitaries. Our second preference is for a sub-region based on the county council area, including both district and unitary authorities.In terms of sub regional boundaries (questions 1 and 2), we believe there should generally be economic sub regions rather than more restricted administrative areas. In our case, that could mean the Thames Valley. This could be defined by the Buckinghamshire, Oxfordshire and Berkshire Grouping (BOB), or could also extend to Milton Keynes.  BOB does seem to have the most internal connectivity, and we would support this. It corresponds to the default Nuts 2 position.We would consider all our neighbouring boroughs (the City fringes) - together with Kensington and Chelsea - to be in the same sub-region as the City of London and to have  Central London characteristics. These therefore include Camden, Islington, Kensington and Chelsea, Lambeth, Southwark, Tower Hamlets, Hackney and the City of Westminster. They all fall within the NUTS2 definition of Inner London.We (Colchester Borough Council) think that the current proposal will disadvantage the real growth points by spreading the benefits of the growth they achieve across other areas which are not putting the same effort into achieving Government targets. We think a better proposal would be to use the economic grouping of the Haven Gateway Partnership (Colchester BC, Babergh DC, Suffolk Coastal DC, Ipswich BC, Tendring DC and Mid Suffolk DC). This would be more realistic and also fit better with regional policy.Corby is part of the Milton Keynes/South Midlands growth area, but we believe that this is too large as a sub-region for the purposes of this scheme, as rewards would be too diluted over such a broad sub-region. The NUTS2 sub-region of Leicestershire, Rutland and Northamptonshire is meaningless in terms of economic development. The key economic development partnership within which we work is North Northamptonshire (Corby, Kettering, Wellingborough and East Northants.), working with the North Northamptonshire Development Company to deliver both housing and business growth. This would therefore be our preferred sub-region, although if this is considered too small then we should be grouped as Northamptonshire, which is a recognised sub-region of the MKSM growth area Response from Cornwall County Council: A focus on established unitary and county areas should take precedence, recognising that County and Unitary Councils are positioned to take a strategic approach to economic development and business growth. In Cornwall in particular, the county will be the appropriate sub-region. As a distinct region soon to become the largest local authority in the UK, it is apparent that Cornwall should be considered as a sub regional area in its own right. Cornwall has the will and capacity to take on new and enhanced responsibilities for both policy and strategy development and the delivery of economic dev< elopment and regeneration. It is not believed that business support, inward investment, support for innovation and responding to economic shocks are best delivered at a regional level and Cornwall reflects, as requested in the consultation document a  real economic area . .The whole concept of grouping means that the contributions of individual authorities are  lost within aggregated figures. This could be a dis-incentive. The conditions that apply to economic development in Bristol are almost certainly different from the remainder of the proposed grouping which includes Cotswold  there are bound to be tensions between the different members of any group. If, however, grouping is to be the basis for the calculations then there is obviously merit in using an existing model and the NUTS2 is probably as good as any other.ROur view is that Coventry should be grouped in the same region as Solihull and Warwickshire for the following reasons: " Coventry, Solihull and Warwickshire is a natural economic sub region " This is recognised in the longstanding and successful Coventry, Solihull and Warwickshire Partnership, an economic development partnership " Economic planning and investment strategies have been at the heart of the work of this partnership for many years " The sub region is a key growth corridor recognised in regional and national spatial strategies " Travel to work patterns show strong economic inter-relationships " There is an established and rapidly growing Coventry, Solihull and Warwickshire High Technology Corridor " The sub region shares the advantages of key economic development assets, including Coventry and Warwick universities, and seeks the development of the same technology sectors for sustainable economic development in the future It is for these reasons that the Coventry, Solihull and Warwickshire sub-region is becoming increasingly important to us relative to that of the West Midlands. EGatwick Airport has significant economic importance for the sub-region; it is suggested that the member authorities of the Gatwick Diamond group should all be in the same sub-region. The districts that make up East & West Sussex and Surrey are very different in nature; there is a mix of urban, rural and coastal authorities.eWe agree with the consultation that using the areas defined by Level 2 of the Nomenclature of Units for Territorial Statistics (NUTS2) is inappropriate in London as this splits London into Inner and Outer London sub-regions. An outer south London borough is likely to have more economic ties with an inner south London borough than a north London outer borough, We agree with the view expressed in the paper that London as a whole should be regarded as the functional economic area and there is not an obvious alternative which takes account of the inter-dependency of the different parts of the London Economy. The answer to this question rests on the logic of the answer to Q3, and is therefore is that the Council s view is that Daventry District forms part of the existing defined Milton Keynes  South Midlands (MKSM) Sub-Region and that therefore the MKSM Sub-Region should be the sub-region for the purposes of LABGI. Using the NUTS2 area (Northamptonshire, Leicestershire, the City of Leicester and Rutland) would clash with the MKSM sub-region and its planning and governance arrangements, inhibiting the effectiveness of both.QDerby City Council regards the other members of the Derby & Derbyshire Economic Partnership (DDEP) as being in the same sub-region for the purposes of cooperation in economic development. The DDEP was established in 2001 by the East Midlands Development Agency  to stimulate, develop and bring forward a range of sustainable economic opportunities in Derby and Derbyshire and improve the prosperity and overall environment for businesses, communities, individuals and visitors . We therefore consider our partners to be Amber Valley, Derbyshire Dales, Erewash, High Peak and South Derbyshire.Dorset is a partner in the Multi Area Agreement (MAA) for Bournemouth Dorset and Poole which focuses on the economic development of this area. We therefore propose that the local authorities which form this economic sub-region reflect the MAA area and consist of: Borough of Poole Bournemouth Borough Council Christchurch Borough Council Dorset County Council East Dorset District Council North Dorset District Council Purbeck District Council West Dorset District Council Weymouth & Portland Borough Council Dover District Council is part of The East Kent Local Strategic Partnership together with Thanet, Shepway and Canterbury and these Councils together with Kent County Council would be our main local authority partners for economic development. Updated response received: Dover, Thanet, Shepway and Canterbury have formed an East Kent Joint Arrangements Committee for the joint provision of services. We also have joint Scrutiny arrangements. We currently share Internal Audit on this basis. Current projects for the additional joint provision of services include: Waste collection and re-cycling HR and Payroll Housing - ie joining in the< 4 HRA's Building control. I think this underlines the extent to which East Kent has its own sub regional identity, and supports our LABGI responses.There is a fundamental issue with this if the scheme is to progress beyond the next 2 years. The presumption is for a sub-regional model only, that could mean we might be in a position where any future gains we generate from our own regeneration intitaitives are marginalised or removed by others lack of regeneration growth or, dependent upon which sub region we are in. Longer term we would prefer it if individual authority regeneration were the basis for LABGI reward.6Because of its shape and geography East Hampshire does not easily fall within a single economic sub-region. The District runs north south from South Hampshire to Surrey/Blackwater Valley and east to west from Winchester to West Sussex (Chichester). Furthermore, its settlement pattern of town and village lie within a number of separate economic areas (as shown by travel to work data - TTWA). This means that East Hampshire (and its constituent parts) lies within at least 3 sub-regions: (i) it is part of the Hampshire community of 14 councils (including HCC) with most of the District being part of the "rest of Hampshire" (or Central Hampshire) in the South East Plan, which includes Test Valley, Winchester, New Forest and the "Deane " of Basingstoke. (ii) 7% of the District, around Horndean, is part of the Partnership for Urban South Hampshire (PUSH) although TTWA extends as far as Petersfield. (iii) The northern part of the District, around Alton and Whitehill-Bordon, has a close economic relationship wtih North Hampshire (Blackwater Valley) and the Western Corridor (M3/M4). Economic Development, for practical purposes, sits within the County of Hampshire with strong strategic links with Portsmouth and Southampton. The rural agenda, market towns, etc is, for practical purposes a focus on Central Hampshire. rEast Sussex, together with other County Councils in the South East, believe that existing county boundaries are the appropriate sub regional unit and will oppose any proposal for larger clusters on any issue (including for distribution of LABGI). The Counties have a strong track record of joint working and, where working across boundaries adds value, such arrangements can and will be made. It is not appropriate for the Government to impose wider units and the inevitable overhead costs that such artificial "clusters" creates. In relation to LAGBI, we have consistently argued that the existing methodology used by the Government for the allocation of LABGI is unfair and this latest proposal does not address those concerns, it just changes the administrative areas. If imposed we will, of course, work with other South East Counties to develop a practical method of working. Eastleigh Borough Council is one of the district councils under Hampshire County Council. It is also a key district in the Partnership for Urban South Hampshire (PUSH), which is an economic development driven partnership of 11 local authorities across the South Hampshire sub-region. It co-operates both at County and sub-regional levels. In response to a request for clarification from CLG: I think my answer was a reflection of the fact that Eastleigh Borough Council works at a sub-regional level as well as co-operating at County level. In terms of LAGBI allocation it probably makes more sense for the financial element to be allocated at the upper tier, county level, as PUSH covers part local authority areas as well as whole ones (as in Eastleigh s case) and it would therefore be very difficult to agree split of funding for part districts. Preference would therefore have to be for Hampshire County council. MNone. Each authority should be calculated on an individual basis, otherwise there is little incentive to improve. One feature of the new scheme would mitigate against the incentivisation of economic development activity, even if the scheme did provide an incentive. This is, the grouping together of authorities in sub-regions. Sub-regions can be very varied in economic development terms and that certainly is the case in Cumbria. It would be increasingly difficult to see how a sub-regional reward could be deemed to influence the individual behaviour of the constituent authorities.One of the key questions in the consultation document is whether we agree that London should be regarded as a single sub-region for the purposes of this scheme, and that might create more consistency over time in the size of LABGI allocations. However, the existing North London sub-region of Enfield, Barnet, Haringey and Waltham Forest would seem to be a sensible sub-regional alternative to which the Council could subscribe.In the spirit of the sub national review, we recognise the importance of embracing properly functioning regions and sub-regions and, at the regional level, have committed to working closely with EEDA in order to make regional and sub-regional dynamics work. We have developed a Greater Essex Economic Framework, covering all District/Borough Councils in the geography of Essex County Council s administrative area plus the unitaries of Southend on Sea Council and Thurrock Borough Council. The Greater Essex Economic Framework sets out broad economic aims for the Greater Essex sub-region, below which it is important to note other sub-regional geographies and partnerships operate. These form around the development areas of Harlow/M11; Haven Gateway; Heart of Essex; and Thames Gateway South Essex (TGSE). As Thurrock and Southend Unitaries reside in the sub-region of TGSE and work closely with Essex County Council, Castle Point Borough Council, Basildon District Council and Rochford District Council through a sub-regional partnership - Thames Gateway South Essex Partnership - the allocation of LABGI reward within Greater Essex must be cognisant of the significant economic influence of the TGSE sub-region. This would bring it in line w< ith the East of England Plan and its policy ETG1. A simple reliance on NUTS2 classifications is therefore not supported as it does not reflect the economic reality of Greater Essex. Vi. GCP  First choice as this is our greatest economic driver ii. Suffolk iii. St Eds and half of Babergh as per existing LSP (but this doesn t meet the criteria) iv. St Eds, parts of Mid Suffolk and Babergh as per LGR Western Suffolk Unitary proposal (but this doesn t meet the criteria) v. Breckland and East Cambs (ARP area) In response to a request for clarification from CLG: The Greater Cambridge Partnership (GCP) area covers: Forest Heath St Edmundsbury Cambridge City East Cambridgeshire Fenland Huntingdonshire North Hertfordshire South Cambridgeshire Uttlesford Cambridgeshire CountypAlthough Fylde Borough Council is part of the two-tier local government map of Lancashire it has a distinct socio-economic makeup which is focused on the Fylde coast, comprising the two borough councils of Fylde and Wyre and the Blackpool Unitary authority. We believe that this is the most appropriate footprint on which to focus future cooperation and collaborative working in economic development. Indeed, this argument is supported by the current work being carried out by the Fylde coast councils on an MAA which is strongly based on the existence of a cohesive and readily identifiable economic community of interest.The Council support the proposal in which local authorities are given the freedom to decide their own groupings to encourage cooperation and partnership working with economic development partners. The Council wish to be included in a sub-region with other Tyne & Wear authorities: Newcastle, Sunderland, South Tyneside and North Tyneside. One of the objectives for reforming LABGI was to produce a stronger, simpler and more predictable link between local growth and local incentives. Creating sub-regions moves away from rewarding local growth to rewarding growth at a sub-regional level. This takes away a great deal from the incentive element of the grant. It implies that local authorities that are grouped together are actively working together to promote economic growth. Also, local authorities who have had nil or negative growth will still receive a share of any reward allocated to the sub-region overall. It should be ensured that the introduction of sub-regions does not create stronger incentives in high growth areas than in low growth areas and should acknowledge that individual authorities will have different abilities to generate resources locally, in particular those areas experiencing high levels of deprivation or a significant proportion of land clearance.We believe that Gloucestershire itself is a functioning economic sub-region for the following reasons: " Gloucestershire has an 87% self containment between jobs and residents i.e. only 13% leakage across our boundaries. Gloucestershire is therefore a sub-region in its own right. " We are not an MAA area. " We ve always been recognised by the SWRDA as an economic sub-region. " There is no  functioning economic sub-region based on Gloucestershire, Wiltshire and North Somerset  it is totally artificial, perhaps only reflecting similar economic performance. This is also consistent with our analysis for possible sub-regional groupings for the transfer of responsibilities from the LSC for 16-18 year olds further education. Our analysis of learning patterns shows 96% of the Gloucestershire students attend one of the County s own colleges. Furthermore, our biggest colleges have 95% and 97% attendance from within Gloucestershire. `We accept that traditionally, Government has placed Halton within the Cheshire NUTs II grouping and also within the NUTs III grouping Halton/Warrington. Therefore, on this occasion for the purpose of allocating LABGI resources we acknowledge that a grouping, which includes Cheshire East, Cheshire West, Chester, Warrington and Halton is appropriate This Council s preference would be for separate sub-regional groupings for Inner and Outer London. There are clear differences between Inner and Outer London in terms of economic characteristics, costs and regeneration opportunities. As a region Inner London contributes over 17% of national business rate income. This compares to a contribution of just under 9% for Outer London. On a per head of population basis, the level of business rates income is over 3 times higher in Inner London than Outer London. This difference is important. Inner London is a key driver of the national economy and has played a prominent part in promoting business growth. LABGI should be rewarding this growth and encouraging further economic development. Treating London as one sub-region will not provide an adequate incentive for Inner London to continue to promote economic development. The knowledge that any potential LABGI gain will be shared across the entire London region will make it a marginal factor when considering if new developments should be taken forward. For LABGI to work as intended local authorities need to be certain that local business rates growth will result in a tangible LABGI reward. Treating London as a single region will not allow for this connection to be sufficiently made. We consider ourselves to be a North London borough that is in a unique< position to be straddling both inner and outer London. Urban densities and transport infrastructure make us a natural extension of Hackney, Islington and Camden to our south, but we do work closely with Enfield, Waltham Forest and Barnet through the sub-regional arrangements established by the previous Mayor.aThe main influence on the economy of this district is our proximity to Leeds and our major cooperation in economic development is around the City Region. In administrative terms however, we are part of North Yorkshire and we assume that the distribution of LABGI grant will be based on the York and North Yorkshire Sub-Region not the Leeds City Region.Given Havering s location on the eastern edge of London, we regard both Essex and our London near neighbours Barking & Dagenham and Redbridge as having similar characteristics We believe London needs to be considered as a whole because economic development depends on many things including: - Opportunities - Infrastructure - Olympics - Housing development opportunities Much of this is determined by the GLA acting for London as a whole. The nature of London is that much of the GLA investment goes in to the centre of London which in turn creates economic growth, however the funding for the GLA comes from London as a whole and hence the financial benefit of the growth should go to London as a whole. However, the reforms proposed in the Sub National Review are designed to strengthen the local authority role in economic development, including support for local authorities in working together in sub-regional partnerships. Havering is part of the Thames Gateway development the largest regeneration project in Europe. A cross-river Thames Gateway sub-region would further demonstrate government commitment to the project and strengthen partnership working to deliver economic development outcomes.vThe NUTS 2 entities are  administrative groupings for statistical purposes not economic groupings which will frustrate economic collaboration so are clearly not appropriate for the purposes of the LABGI scheme. Hertfordshire is a viable economic sub-region in itself. Consequently, Hertfordshire should not be grouped with any other strategic authority - county or unitaryFor the purposes of co-operation in economic development Hillingdon is part of the West London Alliance consisting of the London Boroughs of Hilllingdon, Hounslow, Harrow, Brent, Ealing and Hammersmith & Fulham. This grouping is the main vehicle for sub-regional working in west London. We note that, for no apparent policy reason, the sub-regional approach proposed for the new LABGI scheme contrasts with the individual level rewards provided under the Housing and Planning Delivery Grant. We believe that the whole of London should be seen as 1 functional economic region, in line with the NUTS 1 definition. Travel to work areas cut across inner and outer London, such that the whole of the London region contributes to its economic growth - as such inner and outer London form interdependencies which should not be separated out for the purposes of the new proposed LABGI scheme. Indeed significant infrastructure projects such as Crossrail are being developed precisely because of these key interdependencies.The Council s view is that London should be split into inner and outer London groupings given that these groupings are also applied for Revenue Support grant purposes, and there is a greater emphasis on economic development in inner London than in outer London. Six of the eight London boroughs with highest budgeted economic and community development spend per head in 2008-09 are in inner London. Islington has the second highest economic development spend per head in London.The Royal Borough believes that the London boroughs can in terms of historic and current president be regarded as part of the same sub-region for the purpose of cooperation in economic development. We believe that there are arguments in favour of both options - a single London economic sub-region and an inner/outer London split for the purposes of the scheme. However, we would argue that an inner/outer London split would more closely reflect real economic areas. KCC believes that the right question is being asked, but unfortunately in the wrong context of grant allocation to, ultimately, individual authorities, thus making it effectively, and practically, the wrong question being asked. KCC considers that Kent and Medway combined is a big enough  scale to operate as a sub-region in its own right and likewise KCC recognises that Medway is in the same sub-region for EU purposes. KCC also considers Medway to be a good fit at a sub-regional level for the purposes of cooperation in economic development. Unfortunately whilst that is the wording of the question it is really a question, in the context of this consultation, about a fundamental driver of the proposed LABGI scheme being awarded to individual authorities. KCC believes the underlying test is really  does it make sense for grant allocation to be made at the level of the individual authority if sub regional cooperation on economic development is < to be promoted? . KCC believes that it makes much greater sense to allocate the reward solely at the sub regional level as a single sum, devoid of nominal and notional shares for each authority, which will then require authorities to cooperate over priority setting and ultimately spending. That could involve, for example, a Multi Area Agreement, which would then provide the mechanism for due cooperation on economic development and regeneration. This would appear to offer a more robust allocation mechanism for the underlying grant without compromising in any way the scope for sub-regional cooperation.There is no evidence provided or reasons given to support the need for the grant to be distributed using the sub region groupings. There are two difficulties this distribution mechanism causes which are dealt with in the consultation paper. i) This approach massively dilutes any incentive local authorities have. The I in LABGI!! ii) Secondly It does not direct the resources to where the need is - What is the evidence base to support this proposed change of approach? Hull City Council would regard East Riding of Yorkshire Council as the only local authority within the same sub-region for the purposes of co-operation on economic development. However for functional economic development there are clear differences between the two authorities given Hulls tight urban boundary and the predominantly rural East Riding. Our preference is not to be grouped with any other local authority. It is our view that if the LABGI scheme is intended to reward local authorities for the work they have done to promote economic development within their borders, then the reward should be based solely upon the individual Councils contributions to the NNDR pool. Any other approach (such as  sub regions ) dilutes the reward to those councils which have achieved growth in their business rates base by distributing the benefits of that growth elsewhere. Therefore, whilst we may have sub-regional partnership links with neighbouring authorities we do not feel that it is appropriate to use these as a basis for distributing LABGI funding. -Knowsley Council supports a scheme in which local authorities are given the freedom to decide their own sub-region groupings to encourage cooperation and partnership working with economic development partners. Various factors may influence this decision, including the current working arrangements with Multi Area Agreements. Knowsley is already positioned within the Merseyside sub-region, known as the Liverpool City region, for the purposes of cooperation in economic development amongst others. Therefore, for the purpose of this response to consultation Knowsley confirms that the other local authorities it considers to be in the same sub-region are: Liverpool City Council Halton St Helens Metropolitan Borough Council Sefton Metropolitan Borough Council Wirral Metropolitan Borough Council The view of Lancashire County Council is that the Lancashire NUTS2 sub-region boundaries should be used for the purposes of this scheme and as such, the other local authorities we regard as being included within this sub-region are the twelve district authorities of Burnley, Chorley, Fylde, Hyndburn, Lancaster, Pendle, Preston, Ribble Valley, Rossendale, South Ribble, West Lancashire and Wyre, and the two unitary authorities of Blackburn with Darwen and Blackpool. Our view is based upon the sub-regional classifications used in the development of the Lancashire Economic Strategy, the sub-regional focus of the North West Regional Economic Strategy and work currently being undertaken to develop economic priorities for this area. However, within this sub-regional approach, we would seek the flexibility to address issues or focus resources on differing spatial footprints as appropriate. In the case of Lancashire this could be managed by channelling any LABGI resources through the Lancashire LAA. iWithin the North West there is a well-defined set of sub-regions based on County boundaries which form the geographic building blocks of the Regional Economic Strategy. In the case of Lancashire, the sub-regional partnership comprises Lancashire County Council, the two unitary authorities of Blackburn and Blackpool and the 12 District Councils including Lancaster City Council. This partnership has an Economic Strategy which relates directly to the Regional Economic Strategy. However, it is also recognised that the sub-region comprises five sub-areas, each with their own economic footprint and with varying economic performance. Lancaster District is recognised as a separate sub-area in its own right, with a distinct economic geography, and a relatively self-contained labour market with low levels of commuting with neighbouring areas. Its economic structure and performance has differed markedly from other areas within Lancashire. Whilst there are, of course, linkages to the wider sub-regional and regional economies, economic growth within the District is largely dependent on local factors and especially the performance of local employers - economic inter-dependencies with neighbouring areas are relatively weak. One consequence of this is that the City Council does not generally have firm cooperation arrangements with neighbouring authorities for joint economic development activity, although it is part of the Lancashire Local Area Agreement. It is also worth noting that, in a number of respects, Lancaster District has commonalities with neighbouring South Lakeland which is in Cumbria, a wholly separate NUTS2 area. Therefore, we do not feel that there is an economic justification to view Lancaster District as part of the Lancashire NUTS2 sub-regional grouping for LABGI purposes. Our preference is that it should constitute a qualifying area in its own right. Brighton & Hove City Council does not agree that NUTS 2 areas fit reasonably well with functioning economic sub-regions. There is no analysis to evidence the choice of NUTS 2 to indicate economic activity, and given this we reject the proposal to include the whole of East<  Sussex, West Sussex and Surrey as a functioning economic area. As a response, we propose a sub-region to share LABGI reward funding that is evidenced by employment, housing and retail trends taken from secondary sources: - Employment According to the 2001 Census, Brighton & Hove is a significant net importer of commuters from the east (Lewes district) and the west (Adur district) and a net exporter of commuters to the north (Mid Sussex and Crawley). Five districts within our NUTS 2 geography are highlighted as having significant linkages to Brighton & Hove: - LEWES: Lewes district is clearly part of our functional economic area, accounting for a third of the city s entire commuting population. 3,900 residents commute to work in Lewes district and 7,700 Lewes district residents commute into Brighton & Hove. To the east, the strongest links with the Lewes district are with Saltdean and Lewes town centre. ADUR: The whole of the Adur district, which includes Shoreham, is strongly linked with Brighton & Hove (9,600 total commuters). WORTHING: Approximately 2,800 people commute in to the city from Worthing and 2,200 Brighton residents commute out. CRAWLEY: Crawley provides jobs for around 4,400 of the city s residents, although few jobs in Brighton & Hove are held by Crawley s residents. MID SUSSEX: Overall, more people travel between Brighton & Hove and Mid Sussex to work than between Brighton & Hove and Crawley, but the in and outflow of commuters is quite balanced. Nearly half of Brighton residents who work in Mid Sussex are employed in Burgess Hill. Out of the other districts within our NUTS 2 areas, there are no strong employment links between Brighton & Hove and Horsham, Chichester, Arun, Hastings, Eastbourne, Rother, Wealden, and all of Surrey. Retail A 2005 retail study undertaken for Brighton & Hove City Council showed that the city has a strong market share across the adjacent local authorities from Shoreham to the west, south of Burgess Hill and north to Lewes and Newhaven, matching the employment linkages. Housing Around 60% of household moves within Brighton and Hove each year are people moving from one part of the city to another. However, there are strong linkages between the city and its adjacent Districts, with high levels of out-migration, to Lewes and Adur. By contrast, there is significant net in-migration to Brighton & Hove from London. Brighton & Hove s functional economic area The above socio-economic factors suggest significant economic linkages between Brighton & Hove and the authorities in Lewes and Adur (coastal Sussex from Shoreham in the West to Newhaven in the East), and Mid Sussex and Crawley (the A23 corridor). Given Shoreham Harbour s  Growth Point status it is expected that the links between Worthing and Brighton & Hove will strengthen in the future and that existing links are sufficient to consider both cities operate within the same functional economic area. There is no evidence to suggest Surrey and much of rural Sussex having strong economic linkages. Brighton & Hove City Council would therefore consider the following local authorities to represent our functional economic area: - Adur Brighton & Hove Crawley Lewes Mid Sussex WorthingpThe other issue to comment on relates questions 1,3 and 4 regarding the appropriate area that the reward should be based on. As already mentioned, Aylesbury Vale is part of the Milton Keynes and South Midlands sub-region, which is a government designated growth area, charged with delivering over 200,000 new homes and nearly 200,000 new jobs over the next 20 years. It would therefore make sense that this is the basis of the sub region for calculating the LAGBI reward for this whole area, which would help to reinforce the connectivity of the Government designated sub-region. It would also ensure that the growth required in this area is directly rewarded by returning the funds raised as a result of the business growth, providing further incentives and opportunities for more economic development. In addition, a Multi Area Agreement is being considered for this sub region and allocating the LABGI reward on this basis would help move this activity forward. Therefore the MKSM sub region would meet with the criteria set out in paragraph 35 of the consultation and the Council recommends that this is the approach adopted. Thames Gateway South East Authorities. Whilst our default group would be the whole of Essex, Basildon feels that, especially in the context of business growth, the natural grouping is with the two unitary authorities Thurrock BC and Southend BC and with Castle Point and Rochford District Councils because of their existing joint role in TGSE. I believe those authorities will be making the same recommendation.Economically Hampshire is split into 2 parts, north and south, with the Partnership for Urban South Ham< pshire in the south of the county. Basingstoke and Deane is situated in the north of the borough and our natural economic partners are the districts of Test Valley, Hart and Rushmoor. The north Hampshire authorities are at the early stages of investigation into an MAA. Basingstoke and Deane Borough Council believes that the sub-regional grouping for LABGI should reflect this The Council is currently working jointly on the growth agenda, including economic development, housing, transport and waste management schemes as part of the West of England partnership covering the areas of Bath & North East Somerset Council, Bristol City Council, North Somerset & South Gloucestershire. In addition, it is both necessary and appropriate for us to have ongoing and constructive discussions with other local authorities particularly Wiltshire (in terms of Bath Travel to Work Area and transport infrastructure), Somerset and Gloucestershire. In conclusion, therefore it would make strategic sense to be grouped in the West of England (former Avon) sub-region as joint working and governance arrangements are in place and this has already been recognised by central government funding allocations e.g. growth points, but if it was a wider area we would want it to include Somerset as well as Wiltshire and Gloucestershire.~Bedford Borough Council is currently transferring over to Unitary status, and this coincides with the demise of the current Sub Regional Economic Partnership which covers the Bedfordshire and Luton area. The Borough Council does not view Bedfordshire and Luton as a natural area for cooperation on economic development, due to the vast differences between the economies in Bedford, Luton and the rural hinterland. The Borough Council will be seeking to deal with the majority of matters of local interest through a newly formed economic theme group of the LSP that will operate purely within the boundaries of Bedford Borough. However, where cooperation is appropriate and for issues related to the Sustainable Communities Agenda, the Milton Keynes South Midlands (MKSM) growth area and all its component authorities will be the appropriate spatial area for cooperation In response to a request for clarification from CLG: We confirm that our first preference would be for Bedford as a Unitary to be treated as being on its own in a sub-region for LABGI purposes, with a second preference to be included in a sub-region with other members of MKSMAs mentioned in the introduction the most appropriate area for the London Borough of Bexley in terms of economic co-operation would be the Thames Gateway. This area, however, cuts across the suggestion of a single area for London and includes parts of other NUTS2 groupings and so might be difficult to implement in practice. The next best option would be to regard London as a single sub-region as proposed in the paper - there are no other suitable economic groupings within London. It would be preferable to have certainty as early as possible, so Bexley would prefer the Government to publish the final list of sub-regions after this consultation rather than extending the timescales further.BCCs preferred option is to be grouped with the local authorities included within the Birmingham, Coventry and the Black Country City Region. This sub-region would include the local authorities within the NUTS2 categorisation of the West Midlands and Telford and Wrekin Council. However, BCC understands that there are a number of varied permutations of sub-regional working in and around the West Midlands for the purposes of cooperation in economic development. BCC is therefore not opposed to Solihull, Coventry and Warwickshire working together, nor the Black Country authorities. If needs be, BCC would happily be classed as its own sub-region for the purposes of LABGI.Blackpool believes that the Lancashire county boundary is the natural boundary, so we see all councils within it as being in the same sub-region. In addition, the Local Employment Partnership is in place as a forum. In response to a request for clarification from CLG: We meant it as all authorities within the Lancashire boundary irrespective of type, ie including Blackburn with Darwen unitary authority.In Berkshire there are extremely close economic interdependencies between its si component local authorities. This is reflected in pronounced relationships betwee travel-to-work, travel-to-education, travel-to-retail and business clustering. Conversely there is little documented evidence of economic collaboration betwee Berkshire at the southern extreme of the NUTS2 area and Milton Keynes to its north. This grouping is further supported by the recent creation of the Berkshire Economic Strategy Board (BESB), the sub-regions strategic economic partnership, which has the six Berkshire Unitaries at its core. BESB recently adopted its Sustainable Economi Prosperity Strategy for Berkshire, based on shared challenges and objective facing th sub-region, further underlying the collaborative approach to economic development. This demonstrates an infrastructure currently in place which can be utilised to suppoi and nourish economic growth and development within and amongst the County authorities. Such a support structure is not, nor is likely to be, in place for the propose NUTS2 sub-region. Our strong preference, supported by all six Berkshire Unitary authorities, would be for Berkshire County sub-region. 2The DCLG is proposing either a grouping of all London authorities or of outer London being separate from inner London. Neither of these groupings seem particularly appropriate, as Brent is too remote from most authorities in south and east London to be considered in the same economic regional grouping. However of these two options, treating London as only one region would seem more appropriate. It would be more appropriate to use existing sub-regional groupings in London, such as the West London alliance, if this was agreed by the participating authorities Ashford is a designated growth area. None of our neighbouring authorities in Kent are such designated areas. Ashford therefore has certain  special pressures due to a growing population  financial, economic, social & political  sustained over a long period of time. Additionally, in terms of the influence of economies, the size of Kent as a sub-region is significant. This is why the area has previously been split into further areas that can then have a real < impact 'on the ground'. This is demonstrated by the example of the Area Investment Frameworks, which saw four distinct areas of Kent develop, as well as recent movement into partnering areas to bring local authorities together to deliver services such as Economic Development  this has seen the North Kent, East Kent, West Kent and Mid Kent Improvement Partnerships being formed. These smaller areas provide the ability to tackle common issues and implement manageable interventions, with Kent as an area providing a multitude of issues from the proximity to London at one end to the issues of periphery at the other. We would therefore propose that in areas such as Kent, a subdivision of the NUTS2 areas should be investigated as it would provide greater incentive for local authorities to work in partnership on a more practical geographic area. This would in addition allow decision-making over how any LABGI reward is invested to be taken more locally. If reward is simply made on a county basis then it is difficult to see how district councils can have any influence on how the money is allocated. In response to a request for clarification from CLG: In answer to your question, I confirm that we do not propose Ashford as being a single local authority in a sub-region on its own. However, with reference to the second paragraph in our answer to question 1.... "We would therefore propose that in areas such as Kent, a subdivision of the NUTS2 areas should be investigated as it would provide greater incentive for local authorities to work in partnership on a more practical geographic area. This would in addition allow decision-making over how any LABGI reward is invested to be taken more locally. If reward is simply made on a county basis then it is difficult to see how district councils can have any influence on how the money is allocated." we do propose that Ashford forms part of a "Mid-Kent sub-region" - consisting of Ashford, Maidstone, Tunbridge Wells & Swale. This is the Mid-Kent Improvement Partnership mentioned in the first paragraph of our response. The reasoning for this is our designated growth status and the economic development partnerships formed with these district councils, which therefore seems to fit well with the LABGI scheme intentions.Lincolnshire County Council Lincoln City Council East Lindsey District Council North Kesteven District Council South Kesteven District Council Boston Borough Council South Holland District Council West SussexWorcestershireStrongly prefer single LA basis. If sub-regions, first choice South Worcestershire, second choice county basis (Worcestershire)ZWe do not have any alternative proposals to the default position of the NUTS 2 sub- region London^Councils in the South West of London; Lambeth, Richmond, Kingston, Merton, Sutton and Croydon. WarwickshirevWe believe that all London boroughs form the correct sub region for the purpose of cooperation in economic developmentNSuggested sub-regional areas proposed within annex B under NUTS2 is acceptableSurreySuffolk>Suffolk supports the proposal of using NUTS2 sub-region groupsSomersetQThe City Council is happy with the proposed region of Hampshire and Isle of WightSWe are content for the time being with the Bedfordshire and Hertfordshire grouping. Staffordshire.NUTS2 grouping with all Lancashire authoritiesZHambleton, Craven, Scarborough, Harrogate, Ryedale and NYCC are all part of NY sub-region.Coventry City Council, Warwickshire County Council, all Warwickshire District and Borough Councils and Solihull Metropolitan Borough Council. We request one sub-regional grouping to cover the core Liverpool City Region i.e. Knowsley, Liverpool, St Helens, Sefton, Wirral and Halton.NottinghamshireWe regard North Warwickshire as being in a sub- region of Coventry, Warwickshire and Solihull for the purposes of co-operation on economic development NorthamptonshireThe Council wishes to be included in a sub region matching the Multi Area Agreement. The MAA covers Medway Unitary, Dartford, Gravesham and SwaleNorfolkLeicestershireNLeicester City to join up with the MAA and Economic Development Company areas.NUTS2 Assignment  Essex AreaCornwall[All North Yorkshire Districts, North Yorkshire County Council and the City of York Council.IAllerdale, Barrow in Furness, Carlisle, Copeland, Eden and South LakelandThe Council wishes to be included in a sub region matching the Multi Area Agreement. The MAA covers Dartford, Gravesham, Medway Unitary, and Swale DerbyshireThe consultation document proposes a Derbyshire and Nottinghamshire sub-region. The Council would prefer a Derbyshire sub-region comprising of the 8 district and 1 unitary authority rather than a combined Derbyshire and Nottinghamshire sub-regionDorsetEast Herts does not consider the NUTS 2 statistical groupings to be helpful. It would be more helpful to treat Hertfordshire as a sub-region and not group the county with any other part of the region.North East Lincolnshire Council West Lindsey District Council Boston Borough Council Lincoln City Council North Kesteven District Council Hull City Council, as plans are being made to establish a multi area agreement covering enterprise, skills and employment with this authority. East SussexIt would seem preferable to be grouped with Nottinghamshire as a whole not including Derbyshire. This would seem to be more in line with government policy on city regions.GloucestershireThe Council wishes to be included in a sub region matching the Multi Area Agreement. The MAA covers Dartford Borough Council, Gravesham Borough Council, Medway Unitary, and Swale Borough Council.NY Districts + York HampshireThe County Council supports an approach to grant allocation based on sub-regions and considers the proposed H< ampshire and Isle of Wight area to be an appropriate one.Leicester City. HertfordshireHuntingdonshire (new)BuckinghamshireCambridgeshirelChelmsford is part of a Heart of Essex sub-region consisting of Braintree, Brentwood, Chelmsford and Maldon.;The six districts and the county council in Gloucestershire"Cheshire and Warrington Sub-regionBarnsley is content to support a scheme that allows us to decide upon our own groupings and it makes sense for South Yorkshire Authorities to group together to strengthen existing working relationships.dIn response to the specific question about areas, Members at Bassetlaw have no expressed preference.Bedfordshire CCLuton and Hertfordshire<The proposal to use the Lancashire county area is acceptableFor the purposes of this exercise and to ensure consistency across the country, we believe the NUTS2 grouping (West Yorkshire: Bradford, Calderdale, Kirklees, Leeds, Wakefield) to be appropriate. Local authority respondentSuggested sub-regional partners?Other LAs that include respondent in their suggested sub-regionHertfordshire CC BroxbourneDacorumEast Hertfordshire HertsmereNorth Hertfordshire St Albans Stevenage Three RiversWatfordWelwyn HatfieldBuckinghamshire CCAylesbury ValeChiltern South BucksWycombe OxfordshireCherwellOxfordSouth OxfordshireVale of White HorseWest Oxfordshire Cornwall UAIsles of Scilly Cumbria CC AllerdaleBarrow-in-FurnessCarlisleCopelandEdenSouth Lakeland Derbyshire CC Amber ValleyBolsover ChesterfieldDerby UADerbyshire DalesErewash High PeakNorth East DerbyshireSouth DerbyshireNottinghamshire CCAshfield BassetlawBroxtoweGedling MansfieldNewark & SherwoodNottingham City UA Rushcliffe Dorset CCBournemouth UA Christchurch East Dorset North DorsetPoole UAPurbeck West DorsetWeymouth & Portland Somerset CCMendip SedgemoorSouth Somerset Taunton Deane West SomersetCambridgeshire CC CambridgeEast CambridgeshireFenlandHuntingdonshireSouth Cambridgeshire Norfolk CC Breckland BroadlandGreat YarmouthKings Lynn & West Norfolk North NorfolkNorwich South Norfolk Suffolk CCBabergh Forest HeathIpswich Mid SuffolkPeterborough UASt EdmundsburySuffolk CoastalWaveneyEssex CCBasildon Braintree Brentwood Castle Point Chelmsford Colchester Epping ForestHarlowMaldonRochfordSouthend-on-Sea UATendring Thurrock UA UttlesfordGloucestershire CC CheltenhamCotswoldForest of Dean GloucesterStroud Tewkesbury Hampshire CCBasingstoke & DeaneEast Hampshire EastleighFarehamGosportHartHavantIsle of Wight UA New Forest Portsmouth UARushmoorSouthampton UA Test Valley WinchesterWarwickshire CCNorth WarwickshireNuneaton & BedworthRugbyStratford-on-AvonWarwickCoventrySolihullWorcestershire CC Bromsgrove Malvern HillsRedditch WorcesterWychavon Wyre ForestKent CCAshford CanterburyDartfordDover Gravesham MaidstoneMedway Towns UA SevenoaksShepwaySwaleThanetTonbridge & MallingTunbridge Wells Lancashire CCBlackburn with Darwen UA Blackpool UABurnleyChorleyFyldeHyndburn LancasterPendlePreston Ribble Valley Rossendale South RibbleWest LancashireWyreLeicestershire CCBlaby Charnwood HarboroughHinckley & Bosworth Leicester UAMeltonNorth West LeicestershireOadby & WigstonNorthamptonshire CCCorbyDaventryEast Northamptonshire Kettering NorthamptonSouth NorthamptonshireWellingboroughNorth Yorkshire CCCraven Hambleton Harrogate RichmondshireRyedale ScarboroughSelbyStaffordshire CC Cannock ChaseEast Staffordshire LichfieldNewcastle-under-LymeSouth StaffordshireStaffordStaffordshire MoorlandsStoke-on-Trent UATamworthEast Sussex CC EastbourneHastingsLewesRotherWealden Surrey CC ElmbridgeEpsom and Ewell Guildford Mole ValleyReigate & Banstead Runnymede Spelthorne Surrey Heath TandridgeWaverleyWokingWest Sussex CCAdurArun ChichesterCrawleyHorsham Mid SussexWorthingBedfordCentral BedfordshireHertfordshire CC*Luton UA Daventry*Milton Keynes UA Northampton*Bracknell Forest UA Reading UA Reading UA* Slough UA Slough UA*West Berkshire UAWest Berkshire UA*Windsor & Maidenhead UAWindsor & Maidenhead UA* Wokingham UA Wokingham UA*Wycombe*Bracknell Forest UA* Chiltern*Cheshire East Council!Cheshire West and Chester Council Halton UA* Halton UA Warrington UA"Cheshire West and Chester Council*Knowsley LiverpoolSeftonWirralNottinghamshire CC*Devon CC East DevonExeter Mid Devon North Devon South Hams West DevonTorridge Plymouth UA Torbay UA West Devon* Teignbridge South Hams* Wiltshire Norfolk CC*East Riding of Yorkshire UAKingston upon Hull UANorth East Lincolnshire UANorth Lincolnshire UA Castle Point* Rochford*Bexley Basildon* Essex CC*Bath & North East SomersetSouth Gloucestershire UA*BristolNorth Somerset UASouth Gloucestershire UAGloucestershire CC*Bath & North East Somerset* Swindon UABoltonBury ManchesterRochdaleSalford StockportTamesideTraffordOldhamSalford* Stockport* Tameside* Trafford*Wigan Rochdale* Rushmoor*Portsmouth UA* Eastleigh*Basingstoke & Deane* Hampshire CC* Shropshire Herefordshire UA Redditch*Worcestershire CC* Wyre Forest*Rugby*Warwick*Warwickshire CC* Coventry* Solihull*Malvern Hills*North Warwickshire* Gravesham*Medway Towns UA* Dartford*Kent CC* Blackpool UA*Lancashire CC*Ribble Valley*West Lancashire*Blackburn with Darwen UA*Wellingborough*Aylesbury Vale*Leicestershire CC* Rutland UACorby*Boston East Lindsey South Holland West LindseyLincolnNorth KestevenLincolnshire CCSouth KestevenBarking & DagenhamBarnetBromleyCroydonHaveringHounslow RedbridgeSutton GreenwichLewishamNewham Tower HamletsBrentEalingHammersmith & FulhamHarrow Hillingdon* HillingdonCroydon* Havering* Hounslow* Redbridge*Sutton*CamdenCity of LondonEnfieldHackneyHaringey IslingtonKensington & ChelseaKingston upon ThamesLambethMertonRichmond upon Thames SouthwarkWaltham Forest Wandsworth WestminsterHammersmith & Fulham* Islington*Kensington & Chelsea*Bromley*Camden*Brent* Liverpool*Sefton*Wirral* St Helens Knowsley* Hambleton* Harrogate*Ryedale* Scarborough*Selby*YorkLeeds WakefieldCraven* GatesheadNorth Tyneside*Newcastle upon TyneNorth TynesideSouth Tyneside Sunderland Gateshead*South Tyneside*Telford & Wrekin UA Birmingham* BirminghamDudleySandwellWalsall WolverhamptonBarnsley Rotherham* Doncaster Rotherham Sheffield Barnsley*Brighton and Hove Darlington UA Hartlepool UAMiddlesbrough UARedcar & Cleveland UAStockton-on-Tees UAMiddlesbrough UA*Telford & Wrekin UA*Bradford CalderdaleKirklees Wakefield*Leeds*County councilsBedfordshire and Hertfordshire*Berkshire, Buckinghamshire and OxfordshireCheshireCornwall and Isles of ScillyCumbriaDerbyshire and NottinghamshireDevonDorset and Somerset East Anglia"East Riding and North LincolnshireEssex-Gloucestershire, Wiltshire and North SomersetGreater ManchesterHampshire and Isle of Wight.Herefordshire, Worcestershire and WarwickshireKent Lancashire,Leicestershire, Rutland and Northamptonshire Lincolnshire MerseysideNorth Yorkshire Northumberland and Tyne and WearShropshire and StaffordshireSouth YorkshireSurrey, East and West SussexTees Valley and Durham West MidlandsWest YorkshireLocal authorityXResponse to q<uestions on sub-regional preferences (select cell to view comments in full)No expressed preference2Instructions for sub-regional response spreadsheetThe following spreadsheets can be used by local authorities to check that their consultation responses on sub-regional groupings were received and interpreted correctly by CLG and to view the responses from other authorities. There are two worksheets: - Comments- The authorities that are highlighted green with an asterisk show that those authorities have suggested exactly the same sub-regional grouping as the respondent authority.- Where respondents have suggested several alternatives for a sub-region, only their first preference was recorded in this list.P-  No response indicates that an authority did not respond to the consultation.-  No opinion expressed indicates that a respondent did not appear to give direct responses to the issues raised in Questions 1 and 2 of the Consultation Paper.Automatic filtering is switched on in both worksheets, so that the entry for any particular authority can very quickly be accessed.We encourage all local authorities to use these spreadsheets to see neighbouring authorities views on sub-regional groupings, and as a starting point for engaging in discussion with them in an effort to reach a local consensus about them.^The  Comments worksheet shows the text of the responses given by local authorities to Questions 1 and 2 of the Consultation Paper. This can be used in conjunction with the first spreadsheet to ensure that our interpretation of the response is correct, and also to see if that respondent showed any alternative preferences for sub-regional groupings.- Sub-regional Responses NUTS2 AreaCoastal West Sussex (Chichester, Arun, Worthing & Adur) probably represents the characteristics of our District moreso that the NUTS 2 grouping. This group already works together on economic programmes whereas there has been little if any such relationship between the NUTS 2 grouping.Stockton-on-Tees UA*(As proposed in the consultation document Durham UA Doncaster Council has serious concerns over the calculation of LABGI grants on the basis of sub-regional rather than local economic growth. This change contradicts the central principle of the Sub National Review (SNR), that local authorities should be responsible for driving economic regeneration in their districts. The allocation of LABGI grants on a sub-regional basis will serve to create a disincentive for local authorities in driving local economic growth. The implication of sub-regional allocations is that local authority districts will be dependent (for their allocations) on growth in neighbouring areas with different economic characteristics. This change is unfair and removes the local incentive element of the grant, fundamentally altering the nature of the scheme. Doncaster Council has responded to Government calls to drive economic development through the development of the Economic Strategy, a neighbourhood-driven Work, Skills and Enterprise Programme and through the LEGI-funded Success Doncaster Programme. As a result of these and other initiatives in recent years, Doncaster has built strong momentum in economic growth. The Council is concerned that, if the proposals to allocate LABGI sub-regionally are progressed, there is a real risk that the momentum of current economic growth in Doncaster will be lost. For the reasons stated above, Doncaster Council does not believe that sub-regional LABGI allocations are appropriate. If, however, it is decided that such groupings should be used, Doncaster Council regards the South Yorkshire grouping proposed in the consultation paper (Doncaster, Barnsley, Rotherham & Sheffield) as being the most appropriate for the purposes of LABGI allocation. Doncaster Council engages with the South Yorkshire local authorities on economic development issues such as skills, employment, housing and transport. Doncaster Council is committed to sub-regional collaboration where there is a clear focus and rationale and where value can be added from working at the sub-regional level.  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