In September we submitted a strongly-worded response to the changes to the planning system proposed by the Conservative Government.

We have now responded in detail to the wider changes proposed by the White Paper Planning for the Future. You can see our response below matched to the questions in the consultation. The deadline for responses is 11.45pm on 29^th October. We strongly urge you to respond individually to the proposals.

What the government wants to do would be the most significant changes to the planning system since the current framework was introduced in 1947. This is our chance to ensure that local people still have the most important say in what is built, where and to what standards. Our aim is to ensure more social housing is built to the highest standards, that local democracy is preserved in planning decisions, and that we protect our environment rather than handing over control of it to developers and central government.

Please use our comments as much as you wish. You may find that some of the longer answers do not easily fit within the text boxes in the online form. If you find it easier, use the email address also provided.

 

Planning for the Future. Warwick District Labour Group response to the consultation: see full White Paper here and the online questionnaire itself here Consultation. 

 

Q1. What three words do you associate most with the planning system in England?

Answer 1 Developer-led
Answer 2 Inconsistent
Answer 3 Insufficiently democratic

 

Q2. Do you get involved with planning decisions in your local area?

• Yes
• No

 

Q2 (a) If no, why not?

• Don’t know how to
• It takes too long
• It’s too complicated
• I don’t care
• Other (please specify):

 

I do get involved but not as much as I would if resident views had more weight v developers and decisions were more consistent. Residents have some influence through arguments, numbers, councillors to achieve some decisions applying policy robustly & consistently against the stronger influence of large developers over sometimes weak and poorly led planners. This democratic role should indeed be strengthened if possible by increasing participation and, crucially, the weight given to local views, if evidence-based and well argued. An approach which encourages shallow participation and referendum-style inputs should be guarded against.

 

Q3. Our proposals will make it much easier to access plans and contribute your views to planning decisions. How would you like to find out about plans and planning proposals in the future?

• Social Media
• Online News
• Newspaper
• By post
• Other (please specify):

False choice offered. Social media is clearly more important than it used to be but so are online news, local newspapers  and direct communications from the LPA whether email or post. Further comments are:

1. As now, the posting of notices adjacent to the relevant site and the mailing (where possible emailing) to affected residents. Online access to plans, documents, designs etc is already good in our District but could no doubt be improved along the lines suggested. Some residents however will require physical notices and access to physical documents in order to participate.
2. Briefing documents to be available locally, based on a national template, to help residents understand clearly and succinctly how the system works and how they can contribute.
3. For larger developments at a stage prior to the planning decision process, public consultations should be held mandatorily, as sometimes now by discretion, to test opinion systematically on proposed layouts, design, services etc.

4 For larger developments, also, local newspapers and radio to be briefed by the LPA/developers alongside public notices in these media to ensure wider awareness in the community.

5. Format to be developed to make it easier for concerned residents to be able to make online comments and for their views and numbers given some formal weight alongside Councillors in the planning process (facts and arguments assessed and addressed, plans able to be modified after submission and democratic input, but before decision point reached).

 

The introductory rhetoric is strong on improving local democratic participation – and some of the proposals may be helpful. As so often throughout this White Paper the devil will be in the detail.  For example, how are stakeholders going to be identified and enlisted in the decision-making process? What are the institutional mechanisms that will enable effective participation by people? Empower local bodies, e.g. civic groups, so that they become statutory consultees? The great danger is that existing opportunities for local participation are stifled and replaced with hot air.

 

The overwhelming impression of the Paper is that it will weaken resident influence on the planning process and perhaps that of the LPAs .and Councillors who have ultimate control of the process.   Without carefully addressing the real facts and priorities, strengthening the planning frameworks and Local Authority role and powers first and moving carefully to change and quicken the processes of Plan and approvals later, it risks missing huge opportunities to improve real democratic participation and influence over the direction, mix, quality and delivery of housing over the next ten years and longer.

 

The emphasis seems to be to strengthen democratic input at the plan-forming stage but to seriously weaken it at the planning approvals stage or stages. This will reduce real local influence on what gets built. One obvious objection is that the community involved in the Plan will have changed significantly by the time it is implemented – yet those incomers/young adults will have little voice.

 

The Town and Country Planning Association analysis focusses on the democratic deficit summarised as “The White Paper does not provide a single new right for community participation or a single new opportunity for a democratic moment in the plan-making process but rather reduces both rights and opportunities to participate”. See www.tcpa.org.uk

 

Q4. What are your top three priorities for planning in your local area? (Please select only three answers)

• Building homes for young people
• Building homes for the homeless
• Protection of green spaces
• The environment, biodiversity and action on climate change
• Increasing the affordability of housing
• The design of new homes and places
• Supporting the high street
• Supporting the local economy
• More or better local infrastructure
• Protection of existing heritage buildings / areas
• Other (please specify):

See fuller comments in answer to next question

 

Q5. Do you agree that Local Plans should be simplified in line with our proposals?

• Yes
• No
• Not Sure

Please provide supporting statement

Expanded answer to Q4.

1. For affordability above read building more housing at social rents.
2. Nationally and locally the absolute numbers available have dropped (now less than 10% of housing stock locally), while population has grown and income of the lowest paid 20% has at best stagnated. Security of employment has diminished while fewer secure tenancies are available. Reversing the trend in social housing must therefore be a top priority for planning delivery. Consider suspending Right to Buy to stop further losses in this category at least until mechanisms to replace every social house sold actually work.

 

1. There will be significant environmental and social benefits in co-locating people with jobs (and services) in rebalanced communities.

 

1. Young people will be the first to benefit.

 

1. Indirectly it would also help local authorities deal with homelessness.

 

1. implementing the promises in 1.16 and 1.19 of updating the viability assessment process and ‘ capturing a greater share of the uplift in land value that comes with development’ is a very welcome commitment. It should be given priority now, in order to unlock delivery of more social housing under the current planning system.

 

1. Relaunching significant local authority social housing schemes with or without housing associations, SME or financial partners, is not even considered in the White Paper – yet seems the only way to deliver in volume this most-needed category of housing.

 

2. The quality of design of local new housing is poor. This needn’t be the case as the much-lauded recent developments in Norwich & York demonstrate. At least seven things are urgently needed before many more get built:
3. New mandatory minimum standards for internal space. Starting points are the non-mandatory DCLG guidelines issued in 2015 and the similar RIBA report . Local communities to have power to require higher standards.

 

1. New strengthened mandatory minimum standards for insulation & renewable energy installation in all newbuilds (limited positive statements about energy in the White Paper 1.18 but again needs legislation). Is the target zero carbon newbuilds by 2030 or earlier – it is not clear? Should the national energy standard be passivhaus ?

 

1. Local communities should have powers, currently being blocked by government in their Building Regulation proposals, to require higher and different standards over a shorter timescale not only on energy but on other matters such as on water recycling, district heating and noise

 

1. More balance in the planning process between the influence of local officers responsible for Heritage – both improved new designs and conservation – and those responsible for an efficient and timely planning decision process – at least in areas like Warwick & Leamington with strong Heritage foundations to conserve and enhance through new development, but probably everywhere. At present Conservation reports through the Chief Planning Officer and design policies are inadequately defined with the result that both conservation and design policies are too often poorly applied. Idea in the White Paper for a Chief Officer for design and place making (1.18) may be what is needed when more detail available and should be mandatory.

 

1. Adequate enforcement resources – and where identified powers – to minimise post-approval adverse changes which are too often accepted de facto by the LPA. Commitment to additional powers and sanctions (1.16) looks promising but resources and quality are more important. Above all Enforcement should not report through the Chief Planning Officer but have adequate autonomy to deliver – same structural point as for Design and Conservation.

 

1. New mandatory rules linking density of development more closely to environmental impact to discourage car use and encourage walking, cycling, public transport and well-planned imaginative green spaces. This point is not clearly covered in 1.18.

 

1. Priority given to brownfield site developments (including ways of removing the cost penalties compared with greenfield sites). See CPRE’s well-evidenced and argued views. See CPRE brownfield & CPRE brief

 

The emphases on quicker, updated and fast-tracked assessments of design and environmental impact are not balanced by a clear commitment to establishing proper minimum frameworks in these critical but slippery areas.

 

These seven prerequisites must be in place before any major loosening of the current planning system is started. They could provide ‘quick wins’ if applied within the current system.

 

3. Actions on Climate change taking place or required in Warwick District following a declaration of Climate Emergency are briefly summarised in the answer to Q16 below and supporting measures needed in several other answers. Planning policy should also strengthen the policy framework to protect and encourage wildlife and biodiversity as recommended by many bodies and summarised on the Wildlife Trusts’ planning website here .

Answer to Q5

1. In the long run a more efficient, simpler system no doubt needs to be developed, from the evidence presented. But this should not be seen as a priority, ahead of –
2. strengthening of standards (see answer to Q4 above)
3. structural changes to give better practical balance to the Design, Environmental, Approval and Enforcement objectives
4. developing consensus about how local and national housing needs can be properly identified. see 8a below. It would be highly undesirable to make it easier and faster to produce Plans which deliver the wrong houses in the wrong places

 

2. Our local Plan already pretty clearly identifies areas earmarked for development and it is hard to see much benefit from splitting them into two categories both with a presumption in favour of ‘sustainable’ development. The new proposals might ‘streamline’ outline planning permission in the Growth areas but with the attendant risks of inadequate scrutiny unless 1a. and b. are already robustly in place and a strengthened scrutiny mechanism is developed for the full approval stage.

 

3. Our local Planning system is already reasonably well ‘digitised’ in terms of online access to documents, drawings even videos at times, as well as the contributions from consultees and residents. The issues are around first accuracy rather than absence of data and second consistency of decision-making in the public interest against the current policy framework and local opinion. Strengthening rules and structures will help address these issues.

 

4. Simplifying and streamlining the local Plan in itself will do nothing to address the well-known problems of land banking and protracted buildouts by major developers in order to maximise profits at the expense of meeting local plans or need. The recent Letwin report indicated build out rates of no more than 6% a year, often less on large sites. Few if any of his key recommendations seem to have been adopted in this White Paper. Neither issue is properly addressed in this White Paper yet both have been identified by reputable commentators as important constraints on delivery of housing. See the Letwin Report, Blandy & Blandy on Land-banking & LGA land banking

 

5. Nor will two other tactics by developers dealt with which can often weaken democratic control over developments – post-permission ‘supplementary’ applications and retrospective permissions. Stronger new rules may make it less easy for developers to game the system in these ways – or win at Appeal as the Paper suggests. But these are real and important issues in the system which should be addressed more directly.

 

Q6. Do you agree with our proposals for streamlining the development management content of Local Plans, and setting out general development management policies nationally?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Perhaps a combination of the two which is effectively White Paper alternative 2.16.

 

Q7(a) Do you agree with our proposals to replace existing legal and policy tests for Local Plans with a consolidated test of “sustainable development”, which would include consideration of environmental impact?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Is the commitment elsewhere in the White Paper to update the viability assessment and, crucially, capture a larger share of planning gain for public infrastructure covered by this proposal (see Q4 1e above)? If so, it should state so plainly.  If not, where is it covered ? What are the risks of ‘streamlining’ the environmental impact assessment, which the CPRE fears may be adverse?

 

Q7(b) How could strategic, cross-boundary issues be best planned for in the absence of a formal Duty to Cooperate?

 

What is the evidence that the current Duty to Cooperate is inefficient or does not work ? Without that analysis it is impossible to be sure. What is the alternative to local MOU’s negotiated under this Duty, which worked reasonably well between Warwick, Coventry & Rugby.

 

Q8(a) Do you agree that a standard method for establishing housing requirements (that takes into account constraints) should be introduced?

• Yes
• No
• Not Sure

Please provide supporting statement

 

But the method proposed is not it. It arbitrarily doubles the ONS projections of household formation with little or no rationale. The algorithm so far, as acknowledged, takes little account of constraints, or lack of constraints in a particular area e.g. Green Belt land on the one hand, brownfield on the other (the CPRE evidence of scope for 1m+ brownfield site dwellings, more if sensible urban densities are applied, looks compelling). It does not recognise the risk to sales and profits of what is likely to be over-development of too much and the wrong sort of housing. It gives too little weight to local knowledge and local opinion. Above all, the methodology and weight given to planning for social housing seems seriously inadequate – see next question.

 

The LGA report on the housing market throws serious doubt on the ‘housing shortage’ argument except in London (and that may be changing fast post-Covid) and the gross inadequacy of social housing provision in the overall mix. see LGA report on Local Housing Markets.

 

It is surprising and very disappointing for the overall balance of these proposals, that there is little or no direct reference to LGA – or Housing Association – views in this White Paper and that the Advisory Group behind the proposals are mostly from private developer backgrounds.

 

Q8.(b) Do you agree that affordability and the extent of existing urban areas are appropriate indicators of the quantity of development to be accommodated?

• Yes
• No
• Not Sure

Please provide supporting statement

 

How ‘affordability’ is proposed to be calculated seems highly unsatisfactory. Market signals alone will not pick up the unsatisfied demand for social rented housing from the lowest paid who live and work in an area. There is likely to be serious under-counting of demand of this sort and over-delivery of market housing. It also raised very worrying questions about how the new heavily discounted First Homes may be cross subsidised from the already inadequate delivery of social housing (see Q 24 below).

 

Q9(a). Do you agree that there should be automatic permission in principle for areas for substantial development (Growth areas) with faster routes for detailed consent?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Not unless there are safeguards in place in advance –

1. through much stronger frameworks of standards, structures and processes (both White Paper indicated and others proposed in this submission)
2. at or before the detailed consent stage, for adequate democratic scrutiny and decision-making

 

Q9(b). Do you agree with our proposals above for the consent arrangements for Renewal and Protected areas?

• Yes
• No
• Not Sure

Please provide supporting statement

 

At the least needs to be accompanied by removing permitted development rights in Renewal areas or subjecting them to the mandatory minimum standards, both existing and new, to remove the risk of further sub-standard developments, which are well-documented. See July 2020 report commissioned by the government.

 

Q9(c). Do you think there is a case for allowing new settlements to be brought forward under the Nationally Significant Infrastructure Projects regime?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Much more evidence and options required, including how such schemes are approached today, before it is possible to give an informed opinion.

 

Q10. Do you agree with our proposals to make decision-making faster and more certain?

• Yes
• No
• Not Sure

Please provide supporting statement

 

There will always be circumstances where rigid adherence to deadlines will make for bad decisions. On the whole the current planning approval deadlines are adhered to and where not, often to enable developers to modify proposals after early engagement with LPA or other bodies. Penalties for delay without good reason such as deemed approval are already in place and Planners work to timeliness targets. Local democratic empowerment should not be further weakened

 

Q11. Do you agree with our proposals for digitised, web-based Local Plans?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Hard to disagree – but our local Plan is already pretty much there and so are many others. However significant improvements are surely possible to indexing, navigation and by adoption of a standard format.

 

Very much agree with piloting new digital approaches and delivering greater democratic participation.  However, the emphasis should be on broader information-sharing and debate, not simplistic referendum-style opinion-testing. Citizen’s Juries should be considered for the most significant and contentious elements in a proposed Plan and major applications. Costs would be small compared with costs of development and there could be wins for both sides in better mutual understanding and improved plans.

 

Q12. Do you agree with our proposals for a 30 – month statutory timescale for the production of Local Plans?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Perhaps if the proposed streamlining works.

But current delays in developing Plans are not an adequate reason for imposing tighter deadlines. Government should identify key reasons for delays (which may be down to lack of resources and skills in Local Authorities after 10 years of austerity) and use existing powers and support mechanisms to resolve the issues. Other examples of enabling a period of resource-starvation to a public service in order to justify major so-called ‘reforms’ are not encouraging e.g. the railways.

 

Perhaps the self-assessment plus occasional audit approach might work. Another option may be to develop dynamic local Plans which can adjust regularly to changes in the local economy, housing demand etc perhaps through an annual incremental update with rapid approvals from residents and Ministry, rather than an infrequent major overhaul – but a major overhaul may be required as a backstop from time to time ?

 

Q13. (a) Do you agree that Neighbourhood Plans should be retained in the reformed planning system?

• Yes
• No
• Not Sure

Please provide supporting statement

 

The exercise itself is of great democratic value in local communities. But having a broad-based plan from the lowest level of accountability can also produce better ideas and better local buy-in provided it has adequate influence on the planning outcomes.

 

If the trend towards unitary authorities continues it will be vital to devolve more planning powers to the local level to protect democratic participation. And if funding to that level from the Infrastructure Levy increases dramatically as planned this will probably be essential. See answer 2 to Q 22 b) below.

 

 

Q13 (b) How can the neighbourhood planning process be developed to meet our objectives, such as in the use of digital tools and reflecting community preferences about design?

 

Ensure non-politician resident participation in the process as in Leamington Spa. More digital participation would help no doubt but the key to the success here was widespread community working parties, involving individuals with personal experience and interest, as well as representatives from local community groups, with elected councillors taking little part in the process. An informal type of  citizen juries which worked well.

 

 

Q14. Do you agree there should be a stronger emphasis on the build out of developments? And if so, what further measures would you support?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Shorter timescales fixed for each stage of build-out, not just stage 1. Penalties including streamlined CPO or other interventions as recommended in the Letwin report to ensure housing and especially social housing, is delivered to agreed timings. 16-33 year build-outs are simply a form of indirect land-banking.

 

No actions seem to be proposed in this Paper to deal with direct land banking, especially in areas where local needs especially for low-cost housing are strong ?

 

Q15. What do you think about new development that has happened recently in your area?

• Not sure / indifferent
• Beautiful / well-designed
• Ugly / poorly-designed
• There hasn’t been any
• Other (please specify):

 

To clarify, the majority of newbuild housing has delivered internal spaces below, in some cases dramatically below, the DCLG guidelines. Few have solar panels or heat pumps fitted as standard. Most are undistinguished and some ugly. They are based on design models of 20 or 30 years ago. Most are urban sprawl across former farmland at densities of 30/35 dwellings per hectare, 20-30% below the original garden city standard and probably 40% below the density required to sustain viable bus services. (see CPRE). There are few community facilities and little attempt at providing alternative active transport routes or modes.

 

Q16. Sustainability is at the heart of our proposals. What is your priority for sustainability in your area?

• Less reliance on cars
• More green / open spaces
• Energy efficiency of new buildings
• More trees
• Other (please specify):

Again a false choice is proposed. Comments are :

1. Warwick District has declared a Climate Emergency and has an action plan to reduce carbon emissions to as close as possible to net zero

 

2. We are hampered on new build by weak national planning frameworks and mandatory building regulations [see points above].

 

3. LA’s should have powers to exceed mandatory standards if deemed appropriate locally.

 

4. Traffic emissions are a significant contributor to poor air quality and carbon emissions.

 

5. However, all of this proposed list of sustainability issues will have to be addressed as part of a balanced plan to achieve the environmental, biodiversity and climate change priority given in Q4 above- and will be far from sufficient to achieve such a goal.

 

Q17. Do you agree with our proposals for improving the production and use of design guides and codes?

• Yes
• No
• Not Sure

Please provide supporting statement

 

But the devil will be in the detail – the consistency, quality and authority of the officers engaging with developers on this issue. How far will viability and pressure to deliver units to target timescales undermine this laudable objective ?

 

Only by mandating the Chief Officer for Design and Spaces to balance the authority and objectives of the Chief Planning Officer might this work well.

 

Q18. Do you agree that we should establish a new body to support design coding and building better places, and that each authority should have a chief officer for design and place-making?

• Yes
• No
• Not Sure

Please provide supporting statement

 

See above. Idea of moving from a criterion of ‘no net harm’ to ‘net quality gains’ in the NPPF is a good one and could have a strong positive effect on planning culture.

 

However, the definition of beautiful design is fraught with difficulties. We must avoid reversion to pastiche of former styles and encourage innovation to set our own contemporary standards of beauty allied to essential functional and environmental qualities. So a plurality of approaches should be encouraged with much local engagement.

 

Q19. Do you agree with our proposal to consider how design might be given greater emphasis in the strategic objectives for Homes England?

• Yes
• No
• Not Sure

Please provide supporting statement

 

But not just more imaginative external design and landscape settings – fundamentals like internal and external space, patios/conservatories, balconies (for flats) etc.  Also the use of new materials and the commissioning and placing of appropriate artworks alongside innovative design. Local SME’s need to be incentivised to deliver along these lines. There could be competitions to produce better living both practical and aesthetic.

 

Q20. Do you agree with our proposals for implementing a fast-track for beauty?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Who will decide ? Could become a loophole for clever developers. Could become a licence to build luxury homes where profits are highest – demand perhaps high, but the need probably lowest.

 

Q21. When new development happens in your area, what is your priority for what comes with it?

• More affordable housing
• More or better infrastructure (such as transport, schools, health)
• Design of new buildings
• More shops and/or employment space
• Green space
• Don’t know
• Other (please specify):

 

Again something of a false choice. By affordable we mean housing at social rents.  Design and Green space come second. Infrastructure should be a given for every major development.

 

Q22. (a) Should the Government replace the Community Infrastructure Levy and Section 106 planning obligations with a new consolidated Infrastructure Levy, which is charged as a fixed proportion of development value above a set threshold?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Hard to say yes to this proposal as it stands.

1. Will this approach be appropriate in every area? Do some areas need more – or less – as a proportion because they are already poorly or well-served by existing infrastructure? Or some developments? A national rate may be a straightjacket for local requirements but there could be a national minimum and cap perhaps.
2. Agree it should yield more than s106+current CIL.
3. Interesting proposal to simplify the viability issue by setting a small fixed value for land costs (4.9-4.12) – how small compared with current use value e.g. as agricultural or brownfield land? % uplift on current use value? Double agricultural land value? Backed by CPO and other Local authority powers and arrangements as Letwin recommends? Hard to comment on this important proposal without that level of detail. Much low-cost housing lost in this District due to viability assessments with high land values accepted in the calculation; to what extent will this change?
4. Proposal may be largely moot if the parallel proposal to raise the minimum threshold for such payments from 10 to 50 dwellings in the ‘short-term’ is implemented, if larger developers game the system and if the ‘short-term’ becomes the long-term.

 

Q22. (b) Should the Infrastructure Levy rates be set nationally at a single rate, set nationally at an area-specific rate, or set locally?

• Nationally at a single rate
• Nationally at an area-specific rate
• Locally

 

Q22. (c) Should the Infrastructure Levy aim to capture the same amount of value overall, or more value, to support greater investment in infrastructure, affordable housing and local communities?

• Same amount overall
• More value
• Less value
• Not sure

Please provide supporting statement

Comments on Q 22( b)

Not sure.

1. Perhaps a national minimum with local uplifts where appropriate. More work needed on where or what sort of development merits higher (or lower) rates. See answer to previous question.

 

2. No question has been asked about retaining the 25% sharing of the new Levy with Parish and Town Councils. But it should be. Even at 25% of the current CIL there are doubts about how the level of this new funding stream aligns with budgets and powers at this level of Authority and the scope for waste, and/or delay and confusion over responsibilities. To read the same % across to apply to the new much more substantial Infrastructure Levy makes the doubts stronger.

 

Most of the statutory responsibilities for delivering major Infrastructure rest at present with Districts, Counties, Boroughs and Metropolitan Authorities.  Will powers be devolved to the lowest level to follow the funding, especially if the intermediate tier of Local Authority is abolished, as seems to be the preference (see Q 13a above)?

Or will we see protracted and wasteful negotiations to ‘claw back’ much of the funding required for major Infrastructure schemes? Has any thought been given to this question?

 

Comments on Q 22(c)

See earlier answers. To limit the danger of distortion to developments between neighbouring authorities because of large variations in the Levy, the range of the Levy may need to be constrained nationally. But there must also remain mechanisms for national infrastructure funding from general taxation e.g. for major highways, hospitals etc so that the responsibility is not left entirely to Local Authorities to fund such major public service investments from the Levy or from local taxation – or fail to do so.

 

Q22. (d) Should we allow local authorities to borrow against the Infrastructure Levy, to support infrastructure delivery in their area?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Essential sometimes to ensure infrastructure is in place before build-out starts or has far advanced. Good principle also for front-end loaded delivery of social housing. However current funding from s106 in particular is progressive through the building phase of developments. These proposals make the developer contributions back-end loaded once new dwellings are occupied or sold. No evidence is presented to justify such a change and put even more financial pressure on Local Authorities than currently exists, to ensure that delivery of Infrastructure precedes or parallels the construction work.

 

Q23. Do you agree that the scope of the reformed Infrastructure Levy should capture changes of use through permitted development rights?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Alongside other reforms (see other answers) bringing this category in line with other developments and ensuring they do not deliver sub-standard dwellings, by evading important local and national rules and policies, both technical and qualitative.

 

Q24. (a) Do you agree that we should aim to secure at least the same amount of affordable housing under the Infrastructure Levy, and as much on-site affordable provision, as at present?

• Yes
• No
• Not Sure

Please provide supporting statement

 

1. Call it social housing which most of it already is, or should be.
2. Separate out that critical priority from other categories of so-called ‘affordable’ housing.
3. Ensure the new heavily discounted First Homes are set at a level that do not in any way crowd out social housing provision – one way would be to withdraw the First Home proposal altogether.
4. Windfall profits on sales of First Homes should be clawed back and reinvested in social housing.

 

Q24. (b) Should affordable housing be secured as in-kind payment towards the Infrastructure Levy, or as a ‘right to purchase’ at discounted rates for local authorities?

• Yes
• No
• Not Sure

Please provide supporting statement

 

See previous answer. In-kind payment is the current approach and seems to work. But the alternative may give more flexibility to develop viable social housing in locations both more appropriate and easier to manage. Local Authorities and Housing Associations will be best placed to judge. Leave to local discretion.

 

Why is no clear priority given through this White Paper to the low rent sector for the low-paid ? It’s the elephant in the room throughout the document. LGA’s, Housing Associations and Housing Charities should be heavily involved in the review stage of the Paper following this consultation. In addition, young people cannot easily save adequate deposits for their first home purchase without access to reasonably priced rental accommodation.  A major programme of social housing investment would help far more people both into good and affordable accommodation and on to the first step of ownership, than the First Home proposal.

 

Q24. (c) If an in-kind delivery approach is taken, should we mitigate against local authority overpayment risk?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Land value in price paid for social housing should be no more than double current use value. Independent check on actual building costs.

 

Q24. (d) If an in-kind delivery approach is taken, are there additional steps that would need to be taken to support affordable housing quality?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Stronger national mandatory framework for all housing (see earlier questions).  Agree standards with developer at original outline permission stage to ensure in line with HA/LGA standards and not below standards of adjacent market housing. Checks through monitoring and enforcement officers.

 

Q25. Should local authorities have fewer restrictions over how they spend the Infrastructure Levy?

• Yes
• No
• Not Sure

Please provide supporting statement

 

As with Neighbourhood funds, there is a risk that funds may be used on lower priority projects in good times, rather than put aside for contingencies or future core requirements. Any surpluses built up in one Authority and unlikely to be used could be allocated to local social housing investment as the next question implies, or if the need is not there, to adjacent authorities in a less favourable position to deliver much-needed infrastructure (Duty to Cooperate ?).

Strongly opposed to using Levy to lower Council Taxes, there is always a shortage of public funds to deliver timely improvements in infrastructure.

 

Q25 (a) If ‘yes’, should an affordable housing ‘ring-fence’ be developed?

• Yes
• No
• Not Sure

Please provide supporting statement

 

At present social (not so-called ‘affordable’) housing is a critical need in most areas. Authorities should be encouraged by ring-fencing of these Levies and the opening up of low interest borrowing to initiate building schemes with or without partners.

 

Q26. Do you have any views on the potential impact of the proposals raised in this consultation on people with protected characteristics as defined in section 149 of the Equality Act 2010?

• Yes
• No
• Not Sure

Please provide supporting statement

 

Combined with the earlier short-term changes, these proposals if implemented as they stand are likely to do little to deliver the social housing which we so critically lack and may not even halt the decline. The impact on the most vulnerable in our society, the low-paid, children and the disabled for example, is likely to be adverse.

 

Have you responded to a Government consultation before?

• Yes
• No