Housing and Planning Bill

Written evidence submitted by Places for People (HPB 145)

Places for People

1. Places for People is one of the largest property management, development and regeneration companies in the UK. We currently own or manage more than 148,000 homes and provide services to over 500,000 people. We have assets of more than £3 billion. Our vision is to create aspirational homes and inspirational places. We have a long track record of successful development and a solid reputation for delivering large-scale development in towns and cities. Our approach goes much further than simply building homes. We look at what an area needs to be able to thrive - whether it is new schools, shops, leisure facilities, job opportunities, and access to learning and training or specialist support services. We were named Housebuilder of the year 2013 and Landlord of the year 2014.

2. We welcome the opportunity to submit evidence to the Select Committee’s inquiry on the Housing and Planning Bill.

Our Response

Our response to the Committee’s inquiry focuses on two key areas contained within the Bill:

· The regulatory changes which would be most likely to support a step change in new housing delivery

· Changes to the planning system to support the Government’s house building ambitions

Regulation – what needs to change?

1. Our view is that regulation needs to be drastically scaled back – not least to give registered providers the commercial and strategic freedoms they need to deliver a step change in housing output. We take the view the regulatory framework should be sharply focused on the management of the risk of social housing assets being lost to the sector through financial and governance failings.

2. In particular the Government needs to scrutinise not just those regulatory requirements that are no longer required but also the way in which regulation is enforced. Too often housing associations financial transactions are very considerably delayed because the regulator blocks the transaction until it is completely satisfied it fully understands the implications. These decisions could be drastically sped up if the regulator set clear criteria for those circumstances in which their approval is needed. There is also a need to review whether, in all cases, the staff employed by the regulator have sufficient skill and experience to rapidly appraise complex financial transactions and reach a decision on approval.

3. In addition we take the view that the regulatory framework need not be set out in detail in primary legislation. Currently the legislation governing social housing regulation extends to over 200 clauses. We endorse the Government ambition to drastically simplify these measures and to take powers to change specific measures without primary legislation.

4. There are over 1500 housing associations in England. Rather than seek a one size fits all solution we propose a series of deals with those housing associations that have the capacity and skills to make an impact on new build numbers. These "something for something" deals, based on city deals, will deliver new housing for affordable home ownership at scale and offer regulatory freedoms in return.

Specific propositions

5. We endorse the approach taken by the National Housing Federation that argues for four specific de-regulatory measures. These are:

· The disposals consent regime: giving associations greater freedoms over asset disposals would support more efficient stock management and generate additional receipts for reinvestment in delivery of new supply. The Government should consider how best to amend the existing requirement for the regulator to give consent prior to the disposal of stock in order to reduce bureaucracy and give associations back control.

· Asset management: enabling associations to convert vacant properties from social or affordable rent into other forms of tenure would enable us to better respond to the needs of our tenants and the housing market, while generating additional receipts for reinvestment. The Government should also examine whether historic Section 106 agreements currently restrict and delay active asset management strategies and consider mitigations where required.

· Allocations policies: giving housing associations greater control over who they house would allow them to better meet housing need and drive greater efficiencies. The current nominations regime is outdated and should be removed.

· Rent setting: we recognise Government has a stake in reducing the amount of housing benefit paid to all landlords including social ones. But beyond that Government should not be involved in rent setting, which can distort the market. Housing associations should have the freedom to charge the rents they wish, taking account of market dynamics and their social obligations. In return for this freedom we think it would be logical and reasonable for Government to cap the amount of housing benefit received by housing associations.

6. We believe there are a number of changes to the planning system which can be tackled through the Bill which will support the Government’s house building ambitions.

7. Treat large scale housing developments as infrastructure for planning purposes. Housing needs to be seen as a fundamental requirement for our country that is prioritised alongside energy, transport and water. All energy applications above 50MW are automatically considered at a national level by the Planning Inspectorate. We take the view that larger developments – above say 1,000 homes should be seen in the same way.

8. Amend the Strategic Housing Market Assessment requirements to require local authorities to plan for market rent growth. Our research with the Smith Institute found only 2% of councillors consider new market rent to be a top priority in their area, hampering Government efforts to boost PRS supply. Government should also consider the case for a new market rent use class. This could reduce initial land costs thus making market rent developments more viable.

December 2015

Prepared 14th December 2015