Written evidence from Kent County Council
(ARSS 149)
SUMMARY
1. Kent County Council (KCC) welcomes the opportunity
to contribute to this inquiry and would like to highlight the
following priority areas. We would be very happy to expand on
any aspect either in writing or as oral evidence.
Kent County Council strongly welcomes the Coalition's
Government's decision to abolish the Regional Spatial Strategies
and return decision making powers on housing and planning matters
to locally elected authorities. The decision provides a significant
opportunity for the devolution of funding and function and underpins
the delivery of sustainable and prosperous communities.
There is a strong and continuing need for strategic
planning below the level of regions. The new planning system needs
to put in place a policy solution that addresses those issues
that are wider than local but are vital for strong and prosperous
communities. In this period of financial austerity, any solution
must incorporate the positives and wealth of experience that already
exists. It must capitalise on that knowledge and expertise for
the wider good, building on the statutory roles of individual
local councils.
There needs to be clarity within the planning system
that will give confidence for private investment and for the construction
sector. It is not a time for a reversion to old style structure
plans, but a solution is needed that allows for proper planning
and investment decisions on matters that cross local authority
boundaries and are wider than neighbourhood level. Many of the
key challenges facing the country—housing, economic recovery,
protection of the environment and habitats, climate change, energy,
mineral supply and waste management cannot be addressed solely
at the local level.
County Councils, working together with District and
Unitary authorities as the statutory local housing and planning
authorities, are well placed with their long established history
of delivering and facilitating strategic development to play a
key role in future strategic planning. Kent County Council firmly
believes that effective strategic planning can be achieved with
counties offering a sensible geographic basis for that work, drawing
upon the commercial expertise offered by Local Enterprise Partnerships,
the local input of the family of local government in their areas
and pragmatic dialogue with neighbouring authorities.
As the strategic planning framework seeks to achieve
a balance between competing priorities, it is important that it
remains under clear democratic control. We therefore believe that
while LEPs should be proactively consulted and engaged in the
preparation of strategic plans, policy decisions must ultimately
rest with democratic representatives.
County-level spatial frameworks or infrastructure
plans building upon the District Local Development Frameworks
(LDF) are the most appropriate means for co-ordinating planning,
infrastructure and economic development and conservation policies.
Flexibility is also required locally to allow for and encourage
partnerships between neighbouring counties. The A21 Reference
Group of MPs, Council Leaders, public agencies and business along
the length of the A21 from Sevenoaks to Hastings working together
for shared priorities is an excellent example of this approach.
We believe further clarity is required regarding
the incentivising of house-building and the effectiveness in delivering
objectives, particular in 2-tier authorities.
INTRODUCTION AND
CONTEXT
2. Kent County Council is the largest shire County
Council and has a proven track record as an innovative provider
of public services. As a consistently top-performing authority
it has placed service users at the heart of service delivery,
empowered communities and improved the efficiency of its services.
It strongly supports localism, the empowerment of service users
and residents and the devolution of services to the lowest possible
level at which a function can be undertaken and at which 'practical'
decisions can be made.
3. KCC has been at the forefront of strategic
delivery for many years. It has extensive experience of leadership
and partnership working, particularly on cross boundary issues
that are critical to sustainable communities. It has been a key
player in partnerships with other local authorities, the voluntary
sector and the economic community.
4. As a strategic authority, we continue to plan
for the future. In 2009, with partners, we published our Kent
Regeneration Framework, recognising that regeneration is not simply
economic growth—vital though this is—but about transformation
in education and skills, a cultural renaissance in the county
and an efficient transport system that supports the economy, residents
and business growth. It is also about improved housing conditions,
particularly for the most vulnerable, young and old.
5. Our "Twenty-first Century Kent—Unlocking
Kent's Potential" programme will deliver this agenda,
including integrated strategies for transport, infrastructure,
housing, environment, digital and business. Earlier this year,
it was launched with a joint vision produced by international
architect and urban designer Sir Terry Farrell and KCC Leader
Paul Carter, with a "Twenty-first Century Kent" portrait
of success for the county, making clear our ambitions to connect
the county through high speed rail, road and public transport;
to revive our coastal towns and tackle economic disparities; and
to realise Kent's unique geographical advantage to make it the
natural home of new industries in a Twenty-first Century Garden
of England.
6. Kent County Council is also forging new relationships
with its partners. In 2007 it signed the Kent Commitment between
the Leaders of KCC and the 12 Districts to kick-start new ways
of working together and to save public money. Our Kent Recommitment,
to be published later this year, aims to create a "Kent Senate"
of democratically-elected leaders to act as a Kent-wide body to
co-ordinate and agree shared priorities and progress.
7. We have pushed strongly and consistently for
devolution from national and regional government and from Government
quangos and agencies as described in "Bold Steps for Radical
Reform" published in January 2010.
8. The County Council strongly welcomes the Coalition's
Government's decision to abolish the Regional Spatial Strategies
and return decision making powers on housing and planning matters
to locally elected planning authorities. Kent's Leader has been
at the heart of this process, having held or holding amongst other
key roles, the chairmanship of South East England Councils and
the South East England Regional Assembly.
APPROPRIATE CO
-OPERATION ON
CROSS-BOUNDARY
ISSUES
Need for Strategic Planning
9. Strategic planning is necessary to set out
priorities and provide guidance for those issues that are wider
than neighbourhood boundaries. In the absence of better spatial
planning mechanisms, the RSS played an important role in strategic
planning and planning decisions, providing a bridge between national
and local policy considerations. It provided a tool for the resolution
of difficult over-arching decisions that are fundamental to societies
needs. Strategic Planning is essential to ensure that investment
in major infrastructure meets community need and is provided in
a cost effective manner. It is also necessary to ensure a consistent
approach to environmental protection, climate change and other
cross-boundary issues.
10. KCC welcomes the abolition of the housing
targets, but the RSS also aimed to provide the strategic policy
context for a wide range of development considerations and a foundation
for a sustainable and prosperous economy. These included a policy
context for greenbelt and countryside protection, biodiversity,
built and historic environment, transport/infrastructure, sustainability,
climate change, economic development and regeneration, tourism,
education and skills, along with considerations for mineral and
waste management development. Democratic leadership and guidance
on these issues, at an appropriate level, is fundamental to the
national economy.
11. A number of these matters are embedded in
local development frameworks, but this could be better addressed
in the case of the cross boundary issues, particularly the issues
of mineral and waste management, use of natural resources and
infrastructure provision. Many economic drivers do not conform
to administrative boundaries. For example travel to work areas,
markets for goods and services and migration all cross local and
regional borders. Minerals are not locally sourced and need to
be worked where they are found.
12. Inevitably, local plans are often unable
to fully address many of the strategic and cross border issues.
The loss of wider strategic policies, combined with the potential
of conflicting local policies in some adjoining District and Borough
Council areas results in confusion and parochialism as far as
larger strategic developments are concerned. It also causes general
weakening of wider environmental and countryside protection which
the regional plans (and before that the county structure plans)
provided. Reliance solely upon guidance in PPS documents and streamlined
national policy is too broad brush and fails to provide an appropriate
level of policy detail for site specific matters.
THE WAY
FORWARD
13. County Councils have extensive experience
of working together with Unitary and District colleagues to deliver
and facilitate strategic planning. KCC firmly believes that coordination
by historic Counties working closely with District and Unitary
Councils should once again become a principal function of strategic
planning, mirrored in urban areas by City regions. County-level
spatial frameworks or infrastructure plans building upon the District
Local Development Frameworks (LDFs) are the most appropriate means
for co-ordinating planning, infrastructure and economic development
and conservation policies. Importantly, they offer re-alignment
with well established and publicly understood localities. Local
Districts and Boroughs should rightly retain local direction and
control of housing strategy and delivery through their LDFs, but
work together and with counties on wider spatial and strategic
issues including transport and community infrastructure, national/sub-regional
investment projects, growth points, environment and the planning
and provision of energy (including renewable), water and other
resources.
14. Decentralisation to sub/national city or
county areas across the country would provide a clearly recognisable
and coherent structure to devolve powers from regional government.
Decisions would be taken within the local community wherever possible,
rising through to district/borough, county or city or clusters
of both, the more strategic or spatial the issue or decision became.
This approach would give much greater clarity, connection and
engagement between the tiers of local government in a sub-region.
City and county regions with freedoms and responsibilities are
well placed to balance spatial efficiency and effectiveness with
community identity and democracy.
15. A future strategic planning solution also
needs to allow for partnerships between neighbouring Counties
or between Districts across and within county boundaries. Such
flexibility is needed to ensure that action is well grounded locally.
This approach would remove the constraints of artificial boundaries,
whilst providing a stable geographical base on which local partners
can work together.
IMPLICATIONS FOR
HOUSE BUILDING
INCLUDING PROVISIONS
FOR INCENTIVISATION
16. Whilst there was considerable opposition
to regionally imposed targets, it is important not to lose sight
of the interrelation with infrastructure and the role housing
plays in bolstering local economies in terms of attracting and
retaining population, increasing labour supply, supporting local
businesses and providing construction jobs. The maintenance of
a good supply of housing is essential in order to stop the scarcity
of homes, making them artificially expensive and unaffordable
to large sections of society. While essentially a local democratic
decision, any new solution will need to ensure that the Local
Development Plan documents will not be found wanting in relation
to PPS3 requirements and housing need and supply. This is the
crucial issue for successful working and living communities and
requires close co-operation between the tiers of government.
17. It is also worth remembering that the provision
of homes is not just reliant on house-building. There is a key
role for retrofitting and improving the existing housing stock.
18. Housing growth must be properly planned and
geographically targeted, to enable the necessary community infrastructure
to be in place. Matching new homes with new jobs is a key strategic
function along with the timely delivery of infrastructure to support
the development. Any new planning system must address this. The
provision of good quality affordable housing remains a key issue
for Kent, however centrally prescribed housing numbers are not
the best way to secure this objective. Local planning and housing
authorities should be able to determine their own housing numbers,
based on local need and ambitions for growth. However, in this
world of diminishing resources and with the need to ensure that
infrastructure is adequately provided, there is merit in considering
locally-determined housing growth numbers as a part of a wider
housing ambition for the County. Our Kent Housing Strategy, being
developed by all Kent Leaders, will begin to match housing growth
with infrastructure need.
19. We are seeking further clarity about the
proposed New Homes Bonus and potential tariff arrangements which
will incentivise local authorities to give planning consent and
support the construction of new homes in return for future extra
funding to spend on other local priorities. The details about
this proposal are currently very unclear.
20. Clarity is also sought about the Community
Right to Build. KCC is strongly supportive of local communities
being more greatly involved in decision-making, but this should
be done within the planning process, rather than separate from
it. While accepting the need for democratic flexibility, bypassing
the planning system to provide housing in rural areas could be
fraught with difficulty, given the many complicated factors such
as design quality, landscape protection, heritage and biodiversity
concerns and amenity considerations that are normally carefully
weighed-up within the planning process. Similarly, promoting housing
developments without appropriate legal agreements for infrastructure
contributions and tenure stipulations for local needs etc may
undermine the equitable approach being adopted for other housing
development.
21. The UK planning system seeks to protect the
interests of minorities as well as the wider common good and is
founded on the principle of impartial judgement. Some concern
is therefore raised about determining planning proposals for new
housing by ballot which would undermine the established democratic
process where planning proposals are assessed on a rational, impartial
and accountable basis, with crucial regard to material planning
considerations, probity protocols to remove self interest considerations
and an appeal/challenge mechanism to meet European laws and basic
human right provisions.
IMPLICATIONS FOR
PLANNING FOR
ECONOMIC GROWTH
22. It is clearly important that strategic planning
supports sustainable economic growth, for example by maintaining
an understanding of the opportunities and challenges facing the
economy, ensuring an appropriate supply of employment land and
planning for the infrastructure needed to support economic development.
23. The creation of new Local Enterprise Partnerships
present an opportunity to support this by creating partnerships
of businesses and local authorities over viable economic areas
to identify and drive forward economic priorities. With partners,
Kent County Council is progressing an ambitious Kent and Greater
Essex Local Enterprise Partnership, which will seek the ability
to galvanise resources in support of the delivery of the Thames
Gateway, the counties' Growth Areas and priority locations for
regeneration.
24. We believe that Local Enterprise Partnerships
should have a key role in informing the development of infrastructure
plans or county spatial strategies by bringing commercial expertise
into the heart of the planning framework and by articulating the
infrastructure priorities to support economic growth. It is also
important that neighbouring LEPs and local authorities maintain
dialogue, recognising that economic flows and impacts inevitably
cross boundaries.
25. However, as the strategic planning framework
seeks to achieve a balance between competing priorities, it is
important that it remains under clear democratic control. We therefore
believe that whilst LEPs should be proactively consulted and engaged
in the preparation of strategic plans, policy decisions must ultimately
rest with democratic representatives.
DATA AND
RESEARCH IMPLICATIONS
26. It is vital that planning decisions are made
in the context of up to date and sound evidence. There is also
a need for accurate and consistent data to aid monitoring and
reporting on a range of issues—ie mineral and waste management,
housing and economic development. It is of note that much of the
evidence on which the RSS was predicated remains valid and provides
a sound basis for future decision making.
27. In the case of mineral and waste management,
the Regional Aggregate Parties (RAWPS) which are a partnership
of County Council authorities with responsibility for Mineral
Planning, as well as representatives from the minerals industry
have been very effective and essential in monitoring and reporting
work on aggregate matters. They provide a cost effective solution
to the issue of apportionment necessary to meet the requirements
of Mineral Planning Statement 1 (MPS1). Similarly an effective
Regional Technical Advisory Body (RTAB) exists for waste management
matters and provides a tool to aid national aspirations for landfill
diversion and recycling targets.
28. The new planning framework should ensure
that the role of these Technical Working Groups is recognised
and their functions are retained. They have a proven track record
of partnership working on an important strategic policy area that
crosses District and County boundaries. A duty to ensure co-operation
with the Groups and to have regard to its work in planning decisions
should be a statutory requirement.
CONCLUSION AND
RECOMMENDATION
29. There is a strong and continuing need for
strategic planning below the level of regions. The new planning
system needs to effectively put in place a policy solution that
address those issues that are wider than local but are vital for
strong and prosperous communities.
30. Any solution must incorporate the positives
and wealth of experience that already exists in arrangements which
bridge national and local policy delivery. It must capitalise
on that knowledge and expertise for the wider good. County Councils,
working together with District and Unitary authorities, are well
placed with their long established history of delivering and facilitating
strategic development and infrastructure and their statutory role
on a wide range of strategic matters to play a key role in future
strategic planning.
31. Kent County Council firmly believes that
effective strategic planning can be achieved with counties offering
a sensible geographic basis for that work, drawing upon the commercial
expertise offered by Local Enterprise Partnerships, the local
input of the family of local government in their areas and pragmatic
dialogue with neighbouring authorities.
September 2010
REFERENCES
1. Kent Regeneration Framework Shortcut to: https://shareweb.kent.gov.uk/Documents/community-and-living/Regeneration/Regeneration%20framework%20November%202009.pdf
2. Twenty-first Century Kent—Unlocking
Kent's Potential Shortcut to:
https://shareweb.kent.gov.uk/Documents/community-and-living/Regeneration/21stcentkentnew-3.pdf
3. Bold Steps for Radical Reform - the Big Opportunity
for Local Government and Big Savings for the Public Purse Shortcut
to: https://shareweb.kent.gov.uk/Documents/priorities-policies-plans/bold-steps-for-radical-reform.pdf
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