Memorandum submitted by Northamptonshire County Council (H&R 5 - i)
Written submission to the Housing and Regeneration Bill
I understand the housing and regeneration bill is currently going through the Houses of Parliament.
Northamptonshire County Council has previously submitted to Communities and Local Government, via a response on the new Homes and Communities Agency (HaCA), comments on the proposed new organisation (Part 1 of the proposed housing and regeneration bill). I believe that these comments would be of interest to the Public Bill Committee dealing with the bill and therefore I attach our response.
Key points that I would draw your attention to in the response are:
The proposals suggest that HaCA will be structured on a regional basis with the exception of Thames Gateway which will have its own office. The delivery challenges in Thames Gateway are significant and the County Council recognises their need for a dedicated office. However, the Milton Keynes South Midlands (MKSM) Growth Area is delivering more growth than Thames Gateway and its geography, delivery and investment challenges and opportunity equally justify the provision of a dedicated office.
Working with Government, MKSM partners have established robust structures through the MKSM Inter-Regional Board (IRB) and its sub-groups to manage the growth agenda for MKSM. This is in recognition that a co-ordinated partnership approach with shared objectives is critical to the success of MKSM, lying as it does at the geographical periphery of three regions and therefore dealing with three RDAs, three Regional Assemblies, and three government offices. Under current proposals this would also mean 3 offices with their respective Regional Investment Plans.
Given the scale of growth being accommodated in MKSM and the potential of its economic offer, a dedicated NHA office for MKSM is crucial to support delivery, including an MKSM Investment Programme. This would also complement SNR proposals which emphasise the potential for sub-regional delivery and management of funds to support economic development and regeneration, including where the economic geography falls across regional boundaries or groups of local authorities as is the case for MKSM.
Longer Term Investment Programme
The time horizon for the HaCA Investment Programmes needs to be sufficient to give confidence and certainty to public and private sector delivery partners that investment and capacity will be delivered. They should look in strategic terms towards longer term horizons, in keeping with spatial plans and LDV programmes, as well as committing more short - to medium term investment. This should be a minimum of 3 years but longer term indicative programming (5-10 yrs+) would be preferable, particularly when dealing with large scale delivery and capital investment programmes in the growth areas.
Front-funding of infrastructure / "Banker Role"
Given its unique and specialist role, HaCA should play a key role in the Growth Areas to support mechanisms to fund at an early stage the necessary infrastructure to release growth, including working with partners to share risk through appropriate 'banker' mechanisms where necessary.
Northamptonshire County Council is undertaking work on banker mechanisms with a view to using its prudential borrowing powers. English Partnerships has already demonstrated its ability to deliver mechanisms to front fund infrastructure such as the Bedford Western Bypass where risk was shared with Bedfordshire County Council, and Banker arrangements have also been established to support growth in Milton Keynes. The County Council would be very keen to work with HaCA to develop and pilot banker arrangements and mechanisms which can be employed more widely.
Supporting preparation costs for major capital projects
The costs of design, plan and preparation work (including project management) for major capital projects such as new roads are considerable. However, for key infrastructure projects to come forward at the right time to facilitate sustainable growth, such preparatory works have to be undertaken at an early stage and resources committed. Road schemes in particular can take many years from identification of need to completion. County Council resources for this work are very limited. In a growth area such as Northamptonshire where government funding formulas do not take account of growth and the pressure to secure infrastructure investment to facilitate housing growth is acute the resources for design, plan and preparatory work to get major projects onto the pipeline at the right stage are often not available. This is a critical issue which HaCA needs to recognise, test and address through the preparation of its Investment Programmes and where appropriate, to provide funding support.
Improvements on the Delivery of Affordable Housing
HaCA investment in affordable housing particularly in the larger Growth Areas is critical to the sustainable communities' agenda. The core outcome to deliver plans to increase the supply of affordable housing for rent and shared ownership and increasing low cost home ownership is to be welcomed. Performance management arrangements need to be strengthened. Robust and consistent information on affordable housing pipelines and completions would be helpful as records are generally patchy and base data varies. There is a clear role for HaCA ensuring that information is collected in a consistent way across the country.
There also needs to be a clear link to the Strategic Housing Market Assessments to ensure that their findings are delivered. More effective investment decisions will be made through a more local presence. A logical place to address this is through the LAA with HaCA co-operation and sign-up.
It is critical that there should be no reduction in capacity and expertise as a result of merging the housing and regeneration agencies. Growth areas such as MKSM and Northamptonshire in particular are rapidly moving from a planning phase into a focussed delivery phase.
It is essential at this key implementation phase to ensure continuity of the investment programme and retain and enhance experience and capacity available. This continuity creates the right conditions, through increasing certainty and hence confidence, for higher levels of private sector investment. An excellent example of this is the English Partnerships investment programme in Corby and in particular the Civic Hub. This has also acted as a catalyst to attract funding from other public sector partners including the County Council.
I hope that you find the attached response useful in the Parliamentary process. Should there be any queries, or need for clarification, please do not hesitate to contact me.
Compulsory Purchase Orders (CPO)
Paragraph 2.2 of the consultation document lists a number of objectives including best use of public investment, powers and assets. A crucial, and in the County Council's view under-used, element of this is CPO powers. These need to be used more effectively, including potentially a presumption to use this where necessary, to facilitate major growth projects (on both brownfield and greenfield sites) where these are being frustrated. Experience suggests that project delays also considerably increase costs for the public sector.
The County Council supports the removal of the 'brownfield restriction' for compulsory purchase powers of the new homes agency.
The 'threat' of CPO powers to ensure that growth is not frustrated and housing targets are met should be enhanced on key sites e.g. making it clear to landowners that there is a 'presumption to use' CPO rather than getting to the end of protracted negotiations and then initiating CPO powers as a last resort. Landowners may be encouraged to reach a negotiated agreement more quickly if the threat of CPO is more likely, and with in-house skills/expertise of HaCA presumably it could be twin-tracked at limited cost and risk. If months of negotiations then fail, the CPO process is well advanced rather than being at the beginning of an 18 month / 2 year process and the additional costs that brings.
Proposals in the SNR include an enhanced role for local authority leaders in the scrutiny of the new RDAs through a regional leadership group. Similar arrangements could be introduced to secure greater accountability of HaCA.
I trust that you find these comments and the attached response informative.
Should there be any queries, or need for clarification, please contact me.