The current Planning Gain Supplement (PGS) consultation exercise raises the same fundamental concerns that the Society and many other consultees, raised to the previous PGS consultation. The CLG has for example failed to address concerns about:
In the previous PGS consultation exercise CLG made specific reference to the re-distribution/re-cycling of PGS revenue back to the “local level”. It attempted to set out the broad mechanisms as to how this would work for example, through some form of grant related to the revenue raised, or based on a suitable formula. The Society raised serious concerns and doubts as to how this recycling of PGS to the local level would work in practice.
The Society response states that if a PGS is implemented nationally then 100% of the monies collected locally should be recycled locally to the respective infrastructure and service providers.
CLG's proposed scope for planning obligations remains that of the development site environment approach. Its intention is to define the future scope of planning obligations in legislation using a set of criteria-based tests. The criteria as set out by CLG is considered too restricted and does not cover all those obligations which are usually necessary for the development to take place and which are, by definition, clearly related to the development.
The Society has raised an objection to the proposed criteria-based approach to defining the scope of planning obligations.
Affordable housing is proposed to remain within the scope of planning obligations. To address the problems identified within the current system of the lack of predictability for developers as to the value of the contribution likely to be sought from them, to accompany the contributions from a Registered Social Landlord, Housing Corporation or other funding source, the Government is proposing the introduction of a common starting point in negotiations for the value of the developer contributions to affordable housing to be implemented through LDF’s. Whilst a common starting point would appear to be a positive step in achieving consistency in negotiations on affordable housing, setting that starting point as the making of free-serviced land available, threatens the delivery of affordable housing as in some parts of the country this has been achieved without the need for public subsidy.
Phil Kirby, for the Society, said “we have raised an objection to the proposition that the common starting point for affordable housing contributions is free-serviced land. Ideally it should be houses built and ready for occupation. The developer should incur the full cost of providing a completed property less the amount an RSL could finance from rents/sales proceeds.”