Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Chartered Institute of Housing (CIH) (DHB 33)


  The Chartered Institute of Housing (CIH) welcomes this pre-legislative scrutiny of the draft Housing Bill by the ODPM: Housing, Planning, Local Government and the Regions Select Committee. Our members are involved in a range of activities that contribute to the development and management of sustainable housing and environments and we are please to make this submission to the Committee.


  We understand that the changes to the right to buy that are included in the draft Housing Bill are primarily intended to reduce exploitation by individuals and companies. The CIH is very much in favour of these changes to:

    —  extend the qualification period;

    —  extend the post-sale period during which landlords may require owners to repay some or all of their discount (while making it clear that landlords have the discretion to waive repayment); and

    —  changing the basis of repayment to a percentage rather than a flat rate.

  However, we believe that more fundamental reforms than are planned in the draft Bill are necessary. The CIH and the Institute for Public Policy Research (IPPR) jointly staged a symposium late last year. A briefing paper setting out the key messages and making suggestions for further reforms has since been prepared and is available from the web on: A hard copy of the paper will also be sent through the post along with a hard copy of this submission.

  Conclusions from the debate suggested that the right to buy policy works against a number of Government policies, including:

    —  The target to halt bed and breakfast use for families—councils are renting ex-right to buy properties from previous tenants to sub-let to homeless families and housing associations are buying them from residents for the same purpose.

    —  The aim to narrow the gap between deprived neighbourhoods and he rest of the country through the implementation of the National Strategy for Neighbourhood Renewal—the right to buy continues to remove the better properties from the council stock, giving less choice to prospective tenants and concentrating poorer households in the remaining poorer quality stock in poorer environments.

    —  Sustainable communities—there has been a reduction in the length of tenancy prior to purchase and also in the length of time households stay in their properties post-sale. The right to buy also adds to the problem of disadvantaged, low income social housing tenants being concentrated in particular areas (ie those with less attractive stock that is not sold).

    —  The drive to develop more affordable housing in areas of high demand including rural areas that is one of the drivers behind current reforms to planning policy.

  Suggestions for more fundamental changes to the right to buy, to make it more consistent with other strands of Government policy are made in section 2.2 of this submission.

2.1  Provisions in the draft Bill

  Adopting the proposals in the draft Housing Bill will help to reduce the scope for exploitation, although one loop-hole remains that will allow companies to continue to exploit the policy. Companies that enter into agreements with tenants frequently draw up sub-letting agreements for the period during which the discount has to be repaid, enabling them to have access to the property (to rent out) without buying it. The Bill does not contain any provisions for preventing this from happening.

  CIH therefore suggests that additional provisions are added to the Bill. These should require purchasers who do not occupy the dwelling as their main or principle home during the first five years post-sale to repay a portion of the discount—even if they do not dispose of the property. This could also be at the discretion of the landlord.

  Other changes have recently been made by order to limit the maximum discount available in 41 local authority areas in the south east to £16,000. CIH was disappointed that the reductions were applied to such a small number of areas. Many places outside London and the south east are experiencing high demand for affordable housing (evidence in research for the Joseph Rowntree Foundation published May 2003). At the same time, the most recent figures on the right to buy show a substantial increase in sales in all regions, in comparison with the same quarter last year, with the exception of London which has decreased (see table).
Region2001-02 (Q2) 2002-03 (Q2)
North East1,7112,287
North West2,7063,475
Yorkshire and Humberside3,247 4,449
East Midlands2,3412,486
West Midlands3,0994,436
South East1,8361,898
South West1,2841,425
England total23,777 27,834

  There is a case for reducing the maximum discount available in more areas. The criteria applied when deciding which regions should qualify should be revisited and maximum discounts should be reviewed on a regular basis.

2.2  Scope for further reforms

  Whilst we are in favour of the reforms proposed in the draft Bill, they amount only to minor modifications to adjust outcomes. As explained above, we believe that much more fundamental reforms to the right to buy are necessary to prevent it working against achieving other important objectives. This conclusion was drawn from a debate that was attended by politicians, policy makers, practitioners and leading academics.

  In line with many of the Government's policy directions, it was considered that the overall aims of reforms to the right to buy should be to:

    —  Raise the image of social housing to make it a more attractive housing choice and to support the creation of sustainable communities.

    —  Achieve greater fairness between tenants, including those living in different areas and property types, those able to access different home ownership schemes and those who buy and those who remain as tenants.

    —  Reduce the scope for various types of exploitation.

    —  Avoid reducing local authorities ability to fulfil their homelessness and housing duties.

    —  Promote social inclusion and support neighbourhood renewal.

  In addition to the relatively minor reforms proposed in the draft Housing Bill, two further types of reform have been identified that would help to achieve these objectives. They are not mutually exclusive: it would not be a case of either or, and it would not be necessary to remove the right to buy to introduce any of them. They are set out more fully in the briefing paper, and include:

More flexibility to achieve strategic outcomes

  Local authorities could be given more freedom to act strategically in relation to all tenures, giving them more scope for working around the right to buy and compensating for its more negative effects. A range of freedoms should be considered:

    —  Exempting certain properties from the right to buy and giving these tenants equivalent cash sums if they wish to purchase other properties.

    —  Purchase on a shared equity arrangement, ensuring the property remains available at lower than market cost in the long term.

    —  Right to pre-emption to allow social landlords to re-purchase right to buy dwellings.

    —  Giving local authorities greater financial freedoms, to enable them to make cost effective decisions in meeting housing need.

    —  Measures for reinvesting a higher proportion of capital receipts in housing.

Giving tenants a bigger stake in their community

  Promoting full home ownership is only one way of giving people a stake in their communities. There are ways of extending these benefits to tenants who, after all, have rights that allow them to occupy the property for life in a similar way to owners. Giving tenants who meet certain conditions a financial, or equity, stake related to their tenancy is one way of doing this. Tenant incentive schemes that offer other types of rewards to long-term tenants present another means for stabilising the sector.

  CIH and IPPR produced a joint report A Stake Worth Having that looks at the feasibility of a variety of models for equity stakes. ODPM has since produced its own research on equity stakes for tenants. While we are aware that ODPM is not currently looking at this, we firmly believe there are elements that warrant further investigation.

  Equity stakes could help to promote financial inclusion and a sense of responsibility. Some of the models investigated, relate the stake directly to the value of the property and could, therefore, be considered to be a form of shared-ownership. Other models could be considered as a saving scheme, indirectly related to the property value. Equity stakes and tenant incentives schemes would not necessarily require removal of the right to buy. The two could run alongside each other, giving choice to tenants.

  Until equity stakes schemes are tested on the ground it is not possible to know whether they will work, what will work best or how much they will cost. CIH and IPPR recommend that money is made available to undertake a series of pilot schemes in a number of local settings.


  CIH welcomes the proposals to introduce HMO licensing as a means of raising property and management standards.

3.1  Definition of HMO

  We are in general agreement with the definition of an HMO given in the draft Bill (sections 164-170). We are pleased that there is to be a mandatory element (the criteria for which are presumably set out in secondary legislation) as well as a discretionary element. A number of practitioners have suggested to us that many two storey HMOs are high risk, and that a different definition for high risk "mandatory" properties might be more appropriate. Having the legislation set out in this way will give Ministers flexibility to change the definition if it becomes apparent that many high risk HMOs fall outside the mandatory category and are not, therefore, being licensed. This will also allow local authorities to make judgements about the severity of risk in HMOs in their areas and action that should be taken on non-mandatory HMOs, in line with their strategic housing role.

3.2  Licence-holders

  CIH supports the sections of the draft Bill relating to licence-holders being fit and proper persons. We agree that the definition should be focussed, as it is, on offences that potentially relate to the wellbeing of tenants (section 72 (2)).

  We also welcome the decision to only grant licences to "relevant individuals", as opposed to organisations or agencies. In our opinion, these individuals should also be required to be resident within the UK which would help to solve some of the problems of absentee landlordism. Where the owner or person responsible for financing works to the property is not the licensee, the individuals concerned should be required to set out their respective roles and responsibilities in a legal document or contract. The owner or funding body must agree to provide sufficient funds to keep the property up to standard.

  There is scope for more involvement of the Independent Housing Ombudsman (IHO) who has a good track record in facilitating resolution of complaints and conflicts. We believe that compelling landlords to sign up to the IHO as a requirement of gaining a licence would be a very positive move. This would go some way to demonstrating that the individual is "fit and proper".

3.3  Licences and licence fees

  We agree with the statement that "no licence shall be in force for more than five years". This is a reasonable maximum period. However, we also believe that there may be merit in operating shorter licence periods in borderline cases or where it is considered that there is a risk that the license may be breached. The length of licence should depend on the conditions, standards and risks associated with the property (section 68 (9)).

  HMO licensing will need to be adequately funded. We suggest that the fees should be sufficient to allow the scheme to be self-funding.

3.4  Implementation and enforcement

  The success or failure of licensing schemes will rest largely on how well they are implemented. A mandatory HMO licensing scheme is already in place in Scotland and lessons should be learned from this. Research conducted by Heriot Watt University showed that one year after the introduction of the scheme in Scotland, relatively few licences had been granted. The reasons given point to problems relating to implementation, suggesting that care must be taken to make the scheme work well on the ground.

  More clarity is required on, for example:

    —  The date by which high risk HMOs will need to be licensed.

    —  Whether local authorities will be required to inspect dwellings before issuing licences.

    —  Whether self-assessment by landlords will be acceptable.

    —  Monitoring arrangements.

  Also, there are no transitional arrangements for landlords who are already licensed under an existing scheme. Local authorities that already run HMO licensing schemes must make it very clear to landlords that are already signed up, what the new requirements are (whether discretionary or mandatory), and whether or not they already meet these standards.

  We recommend that guidance is published and that officers responsible for HMO licensing are encouraged to undertake training.


  CIH is broadly in favour of the approach being taken—to allow local authorities to introduce licensing of the private rented sector in selected areas. We are not in favour of licensing for licensing's sake, but for intelligent use of appropriate powers to achieve certain outcomes. For this reason we agree that there should be conditions for designation.

  We also believe that local authorities should be given tools to prevent future owners from letting out the property if they believe this will prevent problems occurring in the first place. This might be possible, for example, through a legal covenant on the property.

4.1  Designation of areas

  The draft Bill makes it very clear that the area must be an area of low housing demand, or one that is likely to become such. Certainly, licensing would be helpful in areas where house prices are very low and that have experienced high levels of house purchase at low prices by opportunistic landlords. It would help to tackle problems of poor management (and poor property condition) in this kind of instance and could also provide a means for local authorities to engage with all private landlords in an area, to achieve positive strategic outcomes for the area.

  However, we consider that there may be other specific circumstances in which licensing might be helpful in improving areas that are in decline, but where the housing is not necessarily in low demand. For example, some parts of inner London could benefit from licensing schemes that form part of a wider strategy for improvement. Licensing might also be helpful in areas where large numbers of students live or for former local authority estates where investment in social housing can be undermined because of high levels of privately let former right to buy properties. We therefore suggest that the actual conditions set out in section 82 are changed to include a wider range of areas.

4.2  Property condition

  The proposal is to licence landlords rather than individual properties, and the Bill concentrates on landlords' management responsibilities particularly in dealing with their tenants' anti-social behaviour. CIH believes that this is too narrow an approach, since the problems vary hugely between different areas. In particular, local authorities need to be able to include property condition elements within the licensing requirements if they believe it is appropriate. In some areas property condition is a major problem. Local authorities will be able to achieve much stronger strategic and operational links between their housing condition enforcement activities and licensing if they are permitted to do so.

  Allowing local authorities to include a property condition element in the licence could have a number of advantages including:

    —  drawing stronger and more strategic links between traditional enforcement activities and licensing—there is a danger with the current proposals that licensing and enforcement remain essentially unrelated;

    —  being a stimulus for local authorities to deal with enforcement in a more proactive fashion, whereby authorities advise landlords of the works they need to do before granting a licence, rather than simply enforcing the law;

    —  helping local authorities to identify where the poor condition properties are and where to focus their attention;

    —  making more strategic use of grants and loans to landlords; and

    —  reducing the costs of inspection and enforcement as visits by local authorities to validate landlord declarations could include a property condition element.

4.3  Timescales

  We have concerns with the length of time the draft Bill proposes it will take to get an area designated for selective licensing. As well as the time taken for consultation and for the Secretary of State to confirm designation, Section 83 (5) proposes that designation cannot come into force until at least three months after confirmation. We cannot comprehend the reason for introducing this additional waiting period and suggest that consideration is given to removing this requirement from the Bill.

4.4  Pilots

  Once the legislation is in place, the Government should make provision for pilots to be run in order to provide some valuable feedback to inform future schemes.


  Sanctions are proposed for dealing with unlicensed properties that should be licensed, but are not, under either an HMO or a selective licensing scheme. These are (i) a fine of up to £20,000 and (ii) no rent is payable by the occupant.

  We consider that a fine of up to £20,000 is acceptable for an offence relating to licensing. However, this should be set out in secondary rather than primary legislation so that it can be more easily reviewed. When considering individual cases, the courts must be required to take on board the number of properties a landlord has that falls short of the licensing standards, otherwise small landlords with one or two properties will be discriminated against compared to landlords that own a large number of properties.

  The sanction of not requiring rent to be paid on unlicensed premises is based on a legitimate principle. We much prefer this approach to reducing or terminating housing benefit, which would discriminate against benefit claimants. It is, though, of some concern because of the potential for landlord harassment of tenants and possible illegal eviction.

  If the principle of "no rent payable" is to be adopted as a sanction, then adequate support mechanisms for tenants will be necessary. There is a key role here for Tenancy Relation Officers (TROs). They will need to follow up all instances in which a licence is not granted, or is revoked, and provide the appropriate information to landlords and support to tenants.

  CIH suggests that there may be an alternative approach that may be a more positive way of dealing with the matter. This would involve the Rent Service setting a lower rent that would depend on the condition of the property. This would be accompanied by agreeing timetable to bring the property up to standard. We believe that this approach, using positive enforcement techniques rather than sanctions, may be more likely to win the support of landlords.


  We are in general agreement with the principle of management orders. However, their relationship with the sanction of imposing a fine is not clear. Will the landlord first be fined and then have an IMO imposed? Or will the fine be used as a first stage and an IMO a later stage in the enforcement process?

  A form of management order is already in use. "Control orders" are used initially as a threat to back up an order asking owners to remedy a breach of the fitness standard. However, local authorities do not often use control orders because they have substantial resource implications. They tend to be an option of last resort.

  In regard to licensing (both HMO and selective), we suggest that enforcement should be a process with a series of sanctions that bite at different points, and each of which gives the landlord an opportunity to comply with the licensing requirements. As it is currently drafted, the Bill misses out useful stages of the process. The Bill needs to make it clear what this process is and how the different elements interrelate. Management orders should be a little used, final sanction.


7.1  Improving housing standards

  CIH supports the introduction of home information packs principally because they will be a useful tool in the drive to improve house conditions. Streamlining the process of buying and selling homes will help to reduce stress for those involved and contribute to the competitiveness of the economy by aiding mobility.

  In particular, we anticipate that the requirement to include a home condition report in the home information pack should encourage sustainable home ownership. While good conditions exist in much of the owner-occupied sector, low income home owners often face severe problems. Over 800,000 owner-occupied homes are classed as unfit for human habitation in England and Wales. Many others are in serious disrepair.

  The point at which homes are bought and sold is an important one in influencing the condition of the stock. At this stage, lenders seek to assess the condition of properties through surveys and will frequently seek to ensure repair works are carried out prior to sale. Purchasers take more of an interest in repair and improvement works before and after sale. It is at this point that buyers will aim to determine the scale of works required and assess the resources available to improve their new home.

  Nevertheless, Government research shows that many potential home owners do not currently give enough thought to the physical condition of the home they are buying. Home condition reports should help to ensure that house prices more accurately reflect the condition of the stock bringing to light any "hidden" costs that are particularly problematic for those on low incomes. Making it the responsibility of the sellers will encourage them to rectify problems before putting their property on the market.

7.2  Achieving decent homes

  In addition to the contents proposed in the ODPM consultation paper, we believe that the home condition report should include a statement as to whether the dwelling meets the Governments decent homes standard (DHS). In cases where a home does not meet this standard it should include a further statement of any works which are required to bring the home up to standard.

  Including information relating to the DHS would support the Government's drive to achieve decent homes. It would provide data against which to assess progress towards achieving the overall objective of a decent home for all that would supplement that collected through the English House Condition Survey. It would also help to spread the "decent homes" message abroad and should, over time, provide an incentive for existing owners to maintain their property to a decent standard.

7.3  Energy efficiency

  Requiring the home condition report to include an energy audit, including SAP (Standard Assessment Procedure) ratings will help towards meeting the Government's targets to reduce fuel poverty and improve energy efficiency. Unexpectedly high fuel bills can also contribute towards difficulties in being able to meet mortgage payments particularly amongst low income home owners.

7.4  Sanctions

  We support the government's intention in the draft Bill to make home information packs compulsory. The benefits of the pack will only be fully realised if all parties in the chain use it. If this is to be effective then it needs to be underpinned by some form of sanction which is easy to administer and difficult to evade.

  We have some concerns about the use of civil sanctions if this will result in appeals building up in the courts.

7.5  The Home Information Pack in low demand areas

  In line with the findings of the research regarding the views of those who would be directly affected, we are not in favour of any special treatment of low demand areas. Lenders and investors are likely to avoid areas where exemptions are in place, effectively "red-lining" them. This is likely to result in an accelerated rate of decline of the area.

7.6  Leasehold properties

  Careful consideration needs to be given to the additional material required where leasehold properties are being sold, in particular in relation to estimates of service charges. Leaseholders will be dependent on the efficiency of their managing agent in providing some of the information and may be disadvantaged in respect of other sellers if they experience delays because they are waiting for their managing agent to respond.

  The original consultation paper (DETR, 1999) referred to the possibility that the Law Society should develop a form containing a summary of the information from the documents in plain English. This would be particularly helpful in making sense of some of the complex documents to be provided by leaseholders.

7.7  Application to Right to Buy (RTB) sales

  We understand that the requirement to provide a home information pack does not apply to "right to buy" sales by social landlords to sitting tenants. This is appropriate given that the sale can only occur between two parties—landlord and sitting tenant—and that the council has no option but to sell the property.

  Right to buy tenants must already be provided with information relating to the value of the property and of any structural defects of which the landlord is aware. In the case of RTB tenants of flats they also have a right to an estimate of future service charges for repairs and improvements which is binding on the landlord. The relevant minister also has the power to intervene in the case of undue delays.

  There would be advantages, however, in encouraging buyers in such circumstances to carry out a home condition report before buying their home. Some right to buy purchasers falsely assume that when buying from a social landlord they are "covered" when things go wrong. A report would help potential purchasers to better understand the responsibilities and obligations of home ownership and may help to prevent subsequent calls on the local authority to buy back properties when structural problems or the need for major repairs become apparent. The local authority could arrange for a home condition report to be carried out and could add these costs to the sale price.

  CIH has called for the RTB to be reviewed and modernised to create a more flexible system linked to local housing markets and local housing strategies. Measures to encourage surveys prior to sales could be addressed as part of this wider review.


  CIH suggests that legislative provisions for a scheme or schemes to safeguard private tenants' deposits could be included in the Housing Bill. This has already been the subject of consultation and we understand that the responses from landlords and letting agents did not give any signs that introducing such a scheme would cause problems to the sector.

  Pilots have also been undertaken, the verdict being that the scheme has been successful in achieving its main objectives—to secure tenants deposits and provide a cost effective dispute resolution mechanism. The main problem with the scheme is poor take up, with the majority of landlords and letting agents declining to join a voluntary scheme. The Government appreciates that probably the only way to ensure landlords sign up to the scheme would be to make the scheme(s) obligatory.

  There is also a logic to introducing legislation sooner rather than later. Some momentum has been gained through the pilots and it is important that those involved are encouraged to build on this. Much has been learned from the pilots and it would be more difficult to set up a statutory scheme from scratch than from the current position. For example, it has become apparent that there is a need for giving advice to landlords (and tenants), and ways for doing this are starting being explored. This kind of activity would inevitably be put in hold and in time the lessons learned would be lost if there was nothing to replace the pilots when they come to an end.

  It would not be necessary to enact legislation even if it were introduced at this stage. Statutory provision could be put in place that allows the scheme to be phased in over a period of a number of years as the detail is developed. This would also allow time for administrative elements of the scheme, such as adjudication arrangements, to be put in place.


  It is not possible to provide full, meaningful comment on how the HHSRS will work in practice, because a number of reports have not yet been made available. These include version 2 of the technical guidance and the enforcement guidance.

  Compulsory purchase of housing will be an important activity in the restructuring of housing markets that is planned, particularly in the nine Housing Market Renewal Pathfinder areas. New criteria for compulsory purchase are set out in section 56 of the draft Bill. These require "each of the residential buildings in the area to contain one or more category 1 hazard" (unless they are "dangerous or harmful to health or safety . . . as a result of their bad arrangement . . .").

  During the Fundamental Review of the Laws and Procedures Relating to Compulsory Purchase and Compensation the CIH made the point that, where housing markets are weak, the reasons for demolishing properties may not always rest on their being unfit. In some instances, dwellings are effectively obsolete, and therefore extremely unpopular, because they do not match the aspirations of people today.

  The provisions in section 226 of the Town and Country Planning Act are being revised in section 73 of the Planning and Compulsory Purchase Bill, and this could provide another way of achieving market restructuring. This will enable local authorities to compulsory purchase where the development, redevelopment or improvement is likely to contribute to the achievement of economic, social or environmental "well-being" in the area. However, there is no established definition of "well-being". If they rest on this legislative route to achieve housing market restructuring, local authorities will need greater reassurance that they would be able to defend their case at Public Inquiry.

  We believe that the criteria set out in section 56 need to be much more flexible, and should refer to obsolescence as a valid criterion for compulsory purchase.


  Section 6 of the ODPM consultation paper, "Increasing the effectiveness of powers to regulate Registered Social Landlords" proposes to give Social Housing Grant (SHG), which supports the provision of new social housing, to developers. To date SHG has only been available to Registered Social Landlords (who are principally housing associations) and who are subject to the regulation of the Housing Corporation.

  Registered Social Landlords (RSLs) have to comply with the Housing Corporation's Regulatory Code which sets out what is expected of an RSL in terms of:

    —  Viability;

    —  Governance;

    —  Management; and

    —  Service Delivery.

  The Housing Corporation has considerable powers to take action against RSLs who are failing to deliver in any of these areas. Indeed some of the other proposals in the consultation paper increase the powers of the Housing Corporation to act effectively in such circumstances.

  A proposal to give SHG to profit making bodies not subject to the code is therefore a significant step, yet the consultation paper is sketchy about the arguments for this and how it will operate. There may, for instance, be a case for SHG being given to developers in certain limited circumstances where they are attempting to incorporate social housing into a new estate they are developing. The argument in the consultation paper does however stress that this is to be done, not to facilitate such approaches, but to challenge "housing associations to compete with private developers on price" suggesting a potentially wide role for developers in the provision of social housing.

  The consultation paper argues that whilst developers will have to meet the Housing Corporation's rules in terms of development standards and rents, the subsequent management of the properties will be "secured through contracts, as they would not be subject to the Corporation's regulatory regime". There are three key areas which CIH believes the ODPM needs to clarify its position:

    —  To date SHG has been given to RSLs on the understanding that their contracts with developers for housing development is on the basis of competition. Thus the SHG is given to RSLs and the competition is then between developers, principally on the basis of price. How will competition arrangements work if developers get the SHG and how will the Housing Corporation ensure that value for money is being achieved? Given that developers currently undertake the development work, where does ODPM see savings being made and what is there evidence for this?

    —  In developing properties RSLs receive SHG on the basis of both development and the long term management and maintenance of the properties. The proposal seems to go against other areas of government policy, such as PFI schemes, as it seeks to separate out the development and long term management of the properties, rather than ensuring that they are both fully considered at the time of planning and development. How will the Housing Corporation ensure that developers design for the long term management and maintenance of the properties, particularly if they do not have to meet the aspects of the Corporation's Regulatory Code relating to service delivery?

    —  If the aim is for competition between developers and RSLs then the proposals do not set a level playing field. RSLs will still be subject to the long term need to meet the Housing Corporation's regulatory requirements, with the on-going costs of compliance which RSLs will still have to bear, but developers will be free from these. If genuine competition is to be achieved, is the aim to move RSLs away from full compliance with the Housing Corporation's Regulatory Code? If so what comfort can be given to tenants that the long term service and governance of RSLs will not decline?

  CIH does also have a concern that at a time when there is a need to focus on the delivery of the ambitious development proposals set out in the Communities Plan, there is to be uncertainty about the arrangements for delivering the social housing aspects of the Plan. We consider that the focus of effort should be on fully encouraging and enabling those bodies who currently have the experience and expertise to develop sustainable properties.

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