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Home > Regional Housing
Strategy > Annex C: Outcome of scoping
paper consultation
Annex C: Outcome of scoping paper consultation
The RHS scoping paper was circulated under cover of a letter from
Keith Barnes on 1 May to all North West local authorities and Local
Strategic Partnerships. The invitation to comment also went via
the Housing Corporation to major housing associations in the region,
and via the North West Housing Forum to other key stakeholders in
the housing field. The total number of consultees was about 140.
The scoping paper was also circulated to, and discussed by, the
North West Rural Affairs Forum steering group, and a resulting paper
used to inform the drafting of the Strategy.
51 respondents offered comments by the deadline of 31 May, split
as follows:
- 19 individual local authorities
- 5 partnerships representing one or more local authorities and
other local housing providers
- 1 Local Strategic Partnership
- 15 individual housing associations
- 11 other organisations (including mainly special interest groups
such as Council for the Protection of Rural England (CPRE), the
Countryside Agency, the Disability Rights Commission, the Wildlife
Trust etc.)
Consultees were invited to comment on a proposed "Vision"
for the Regional Housing Strategy and four overarching strategic
housing priorities for the region, including their relative priority.
The list of written responses is attached.
SUMMARY
No respondents queried the fundamental approach envisaged
by the scoping paper. Indeed, the vast majority offered explicit
broad support. All respondents who expressed an opinion agreed that
closer alignment between the RHS and other regional strategies was
beneficial. Nine respondents (a mix of district councils and housing
associations) agreed both the vision and the priorities (including
their ranking relative to each other) as set out in the scoping
paper.
The "Vision"
There was broad agreement to the thrust of the "vision"
as proposed and to its level of ambition. Several respondents offered
alternative versions. Two favoured inclusion of the word "affordable".
Two suggested replacing the word "neighbourhoods" with
the word "communities".
The Regional Priorities
General
Apart from the nine respondents (above) who agreed the priorities
as set out, several respondents favoured a slight change in levels
of priority. Six respondents suggested the inclusion of an additional
priority on Black and Minority Ethnic issues. These include the
Association of Greater Manchester Authorities (AGMA) and five AGMA
members responding separately. The other point on which a number
of respondents agreed was the merging of Priorities 1 and 2 (so
as effectively to have one priority for housing market dysfunction
and treat issues around both low and high demand for housing as
being of equal importance). Four respondents suggested this, including
the Cumbria Housing Group (representing all local authorities and
key housing associations in the county). One respondent (Chorley
BC) suggested an additional priority "sustaining housing markets".
Priority 1
This was broadly supported. Nine respondents (mainly Cheshire
District authorities and housing assocations) said that the priority
areas should be determined by reference to other than the Neighbourhood
Renewal Fund e.g. that CURS ward-level data could be used to identify
areas of deprivation in areas which do not attract Neighbourhood
Renewal Fund and which are outside the Housing Market Renewal Fund
(HMRF) Pathfinder areas.
AGMA, Bury MBC and Tameside MBC said that priority should be given
to those local authorities on the periphery of existing HMRF Pathfinder
boundaries, while Manchester CC said that resources would be spread
too thinly by going beyond the Pathfinder areas. The Merseyside
Policy Unit suggested that a balance needs to be struck and that
too targeted an approach may risk market collapse in non-targeted
areas.
Priority 2
A number of respondents suggested that constraints within the
planning system meant that extra resources would be required to
deliver affordable housing. In particular S.106 was seen as an inadequate
means of providing an adequate supply of affordable housing by several
local authority respondents (a) in the context of reduced overall
provision required by Regional Planning Guidance (Lancashire CC,
Countryside Agency), and (b) because it is difficult to deliver
on the ground (Stockport, Trafford, Wyre). Warrington said that
using s.106 served to deliver a large number of units of which there
was already an oversupply in the Borough. Three respondents (Sefton
MBC, the Cumbria Rural Housing Trust and CPRE) said that greater
flexibility was required in the application of the Total Cost Indicator.
All but one of the six respondents (Chester CC) who expressed an
opinion, said that it was important to identify rural issues as
a separate strategic priority.
Two respondents suggested that market towns should be identified
as priority areas.
Priority 3
Chester CC said that homelessness should be included as an issue
within this priority.
Manchester CC said that the scoping paper focused too much on the
elderly at the expense of other vulnerable groups, although Wulvern
Housing Trust (in Crewe) identified housing for the elderly as the
highest priority for the region.
All respondents who expressed an opinion (twelve) said that investment
should be targeted primarily to identified areas of local need rather
that to existing regeneration programmes, although the East Lancashire
Partnership and the Merseyside Policy Unit said that it was important
to make links with regeneration strategies.
Priority 4
Four respondents suggested this should not be the lowest
of the four priorities. Ten of the fourteen respondents who expressed
an opinion said that this priority should not be subsumed
within Priority 1. These include nine local authorities and one
housing association.
Seven respondents said that the Single Housing Pot should not
be used to support delivery of the Decent Homes priority, two said
that it should and four said that it should but only in certain
circumstances.
Several correspondents drew a link between decent homes and wider
regeneration activity and suggested that this needed to be made
more explicit in the document.
Two respondents suggested that the wording should be changed from
"Decent Homes" to "Decent Places" so as to reflect
wider concerns not just about the physical infrastructure but also
about the wider environment .
Other points
Seven respondents suggested that the Strategy would need to
widen its scope (e.g. to include discussion of such issues as health,
crime and transport).
Several respondents said that clarification was needed between
identified strategic priorities and the resource allocation process
Three respondents (the Merseyside Policy Unit and two of its members,
Liverpool CC and Knowsley MBC) suggested that the strategy should
address the issue of energy efficiency and fuel poverty.
Two respondents (Liverpool CC and St Vincents HA) suggested that
the strategy should include more reference to demographic change
(eg de-population, ageing population etc).
Two respondents said that the document should give more weight
to the issue of skills capacity in the construction industry and
Egan compliance.
Several respondents mentioned the lack of reference to homelessness.
Warrington BC said that reference should be made to Gypsies.
The Wildlife Trust said that reference should be made to the use
of green space.
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