Affordable Housing: Supply and Delivery Review (S.R.14/2021): Joint response of the Minister for the Environment, Minister for Housing and Communities and the Chief Minister

Findings

Comments

A1

It  is  apparent  that  the  Affordable Housing Gateway eligibility criteria is too restrictive and prohibits legitimate access to individuals in need of social housing. There is, however, concern that  widening  the  eligibility  criteria without  much-needed  supply  of housing will lead to longer wait times for those on the waiting list. Work is being undertaken by the Minister for Housing and Communities to consider expanding the criteria and it is pledged that this work will be complete and acted upon during 2021.

The Minister for Housing and Communities has addressed  this  issue  in  his  Fair  Rents  Plan, published in December 2021.

A2

As well as demand for first time buyer properties,  there  is  also  increased demand  for  smaller  homes  for retirees' who feel there are no suitable options available on the market which would enable them to right-size' into from their larger homes. It is a policy intention of the Minister for Housing and Communities to encourage right- sizing  whereby  home-owners  can move to a smaller, more appropriate home for their needs and, in doing so, release a larger family unit onto the market. However, some stakeholders expressed  the  view  that  the  sites proposed in the Draft Bridging Island Plan  to  meet  the  Island's  housing needs, are not reflective of local parish need.

Noted.  The  Island  Plan  takes  an  island-wide approach  to  enabling  right  sizing  which  may differ between individual parishes

A3

It is acknowledged by the Minister for Housing  and  Communities  and Government  Officials  that  further qualitative  work  should  be  done  to establish Islanders' changing property aspirations, particularly given that the pandemic  is  likely  to  have  been  a catalyst  for  changing  Islander's aspirations and expectations regarding certain  property  types  and  features. This analysis will be important in order to  keep  pace  with  future  housing demand.

Noted

A4

The Draft Bridging Island Plan 2022- 25  seeks  to  address  concerns  of  an over-concentration of a particular type, size or tenure of housing and whilst there is a focus on flatted, high density development,  policy  H4  intends  to address  existing  concerns  of  a  high concentration  of  exclusively  smaller bed  size  units,  promoting  a  more diverse mix of occupants within the community.

Noted

A5

Some stakeholder views expressed a lack  of  confidence  in  the  Bridging Island  Plan  housing  delivery  targets being  met  over  its  lifespan.  One housing provider expressed the view that  whilst  the  affordable  housing delivery target will likely be met, it is unlikely that 1,500 affordable homes is sufficient to meet demand.

These matters were considered further in the by the  Independent  Inspectors  and  will  be considered when the Island Plan is debated by the States Assembly.

A6

Jersey  Development  Company recognises the need to encourage right- sizing options, as well as the role it can play  in  supporting  this  to  provide  a product that people may wish to right- size into. JDC acknowledge that this presents an opportunity if those people wish to live within St. Helier and the amenities  it  provides.  Conversely,  it may present a challenge if they have lived in other parishes and their desire is to remain within that community.

The  Minister  for  Housing  and  Communities welcomes this and supports the plans of SoJDC.

A7

The evidence and views provided by some parishes does not appear to have been taken on board fully during the Draft  Bridging  Island  Plan  process, which has led to sites being proposed in  the  Plan  which  do  not  reflect evidenced local parish housing need. Sites suggested by some parishes have not been included in the Plan and there are also concerns that the sites which are  proposed  will  not  cater  for  the appropriate  proportion  and  mix  of housing by type, size and tenure.

The process to develop the Island Plan was fully inclusive of all stated Parish views and included several  rounds  of  bilateral  meetings  with  all Constables.  The  Plan  is  required  to  meet  the island-wide  requirements  for  sustainable development and as such it is inevitable that it may not accord directly with the specific wishes of every Parish.

A8

Build-to-rent  provides  a  potential opportunity  and  role  for  the  private sector to assist in contributing to the delivery and supply of decent housing, and at scale. It differs from buy-to-let on the basis that it is built and designed specifically for tenants and offers the best  design  standards,  facilitates placemaking  and  promotes  better community living and facilities. It also offers  prospective  tenants  better security of tenure than traditional buy- to-let. Further research will need to be undertaken to assess whether there is appetite for build-to-rent schemes, as well as how to ensure scheme viability.

Noted

B1

The  Council  of  Ministers  is considering short term interventions to reduce competition in Jersey's home ownership market and address growing issues with housing affordability. It is the intention to ensure that any policy interventions are data led to ensure no unintended consequences for Jersey's Housing Market.

Noted

B2

Action has been taken by the Minister for  Housing  and  Communities  to freeze social housing rents for 2022. Plans under Action 3D of the Housing Action Plan to address excessive rent rises in the private rented sector are not planned until towards the end of 2022.

The  Minister  for  Housing  and  Communities addressed these issues in his Fair Rents Plan, published in December 2021.

B3

The Dwelling-Houses (Rent Control) (Jersey)  Law  1946  law  makes provision  for  a  constituted  rent tribunal; however, such a tribunal no longer exists. It is thought that this is due  to  tenants  fearing  repercussion from landlords for taking them to a tribunal.  Moreover,  the  Law  is outdated  and  requires  updating  to ensure  it  is  fit  for  purpose. Notwithstanding this, the function of the rent tribunal is still available for reconstitution.  The  Minister  for Housing  and  Communities  has committed  to  looking  into  this  as  a priority and aims to provide certainty on this by the end of 2021 / Q1 2022.

The  Minister  for  Housing  and  Communities addressed  this  issue  in  his  Fair  Rents  Plan, published in December 2021. This includes a commitment to reconstitute the Tribunal in 2022.

B4

The  Government  of  Jersey's  current definition  of  affordable  housing outlines  various  criteria  for  defining both  affordable  rent  and  affordable purchase,  however,  it  makes  no mention of relating housing costs to income levels.

Noted.

B5

Some Islanders are of the view that the 90%  of  market  rent  policy  is contributing to the inflation of private sector rents. Andium Homes does not believe this to be the case based on advice they have received from their economic advisors.

The Minister for Housing and Communities has not  seen  evidence  that  the  90%  rent  policy contributed to inflation in private sector rents.

B6

It  is  Andium  Homes'  view  that charging less than 90% market rent for social housing will not directly impact the  affordability  of  their  homes  for tenants on the basis of the role played by income support payments. 34% of Andium's tenants have their rent paid by income support and 60% have some level of payment from income support to  cover  their  rent.  These  income support  payments  to  Andium  total £17m and are eventually paid back to Treasury  when  Andium  make  their £30m  annual  return  to  Government. This results in a £13m surplus being paid back on top of the income support payments.

The  Minister  for  Housing  and  Communities addressed  this  issue  in  his  Fair  Rents  Plan, published in December 2021.

B7

House  price  rises  have  made  it increasingly  difficult  for  individuals and/or  couples  on  a  middle-income salary to purchase a 1-bedroom home and  high  rental  costs  make  it impossible for them to be able to save for  a  deposit  on  a  home.  Scoping research  into  suitable  affordable purchase  products  has  begun  and  is anticipated  will  be  delivered  by Government  by  mid-2022,  although the last update the Panel received was that this work was still in the scoping stage  and  had  not  yet  been commissioned. It is therefore uncertain whether the target date of mid-2022 will be realised.

The  necessary  research  will  conclude  in  Q1 2022,  and  the  Minister  for  Housing  and Communities will set out his intentions once this has been considered.

B8

Jersey's  highly  competitive  property market is creating a surge in pent-up demand which cannot keep pace with supply,  leading  to  an  overheated housing  market  with  imbalanced supply  and  ultimately  resulting  in increasing property prices.

There are a range of factors contributing to the imbalance between supply and demand. This is why the Minister for Housing and Communities has  taken  a  whole-system  views  across  five priority  areas  in  his  Creating  Better  Homes action plan. The Bridging Island Plan seeks to increase supply significantly.

B9

There  is  anecdotal  evidence  that suggests the demand for, and purchase of, buy-to-let properties by investors may be contributing to higher property prices,  and  also  the  availability  of affordable  properties  for  first  time buyers. The Minister for Housing and Communities  has  committed  to investigating the issue further with a view  to  addressing  the  issue  with appropriate controls and conditions on buy-to-let purchases.

This research will conclude in Q1 2022, and the Minister for Housing and Communities will set out his intentions once this has been considered.

B10

Jersey Development Company's view is  that  the  opportunity  to  purchase should now be focused on the owner- occupier, as opposed to buy-to-let. In order to achieve this, there will need to be  a  reassessment  of  how developments can get past the pre-sale hurdle'  as  previously  there  has  not been  sufficient  numbers  of  owner- occupiers coming forward to achieve the  level  of  presale  required  to commence the build. It is only once developments are at the build stage that more owner-occupier sales are usually generated.

B11

The  scale  and  impact  of  High-Net- Worth individuals moving to the island and being able to own additional rental property  under  certain  conditions  is unknown,  however,  it  is  anecdotally thought  to  be  having  a  detrimental effect  on  inflating  housing  market conditions. It is further unknown how the policy is being enforced and the Minister  for  Housing  and Communities is in agreement that this should be looked at.

Noted.

B12

Jersey  Development  Company  took the decision approximately 18 months ago  to  prevent  any  further  sales  to overseas  purchasers.  However,  the common structuring of their apartment developments  tends  to  be  via  share transfer and whilst action can be taken to prevent that sale to foreign investors on  the  first  transaction,  onward transactions are then not preventable. The South Hill development and future JDC developments will, however, be structured as flying freeholds, meaning sales  can  only  ever  be  made  to residentially qualified individuals.

Ministers  have  now  taken  action  to  ban  the creation of new share transfer units, as promised in the Creating Better Homes action plan.

C1

There are competing tensions between the  need  to  build  more  affordable homes and where to locate them. It is recognised that land is in short supply, however there is also public concern for loss of green space and fears of urban sprawl'.

The  Bridging  Island  Plan  provides  a  policy framework that seeks to respond to and addresses this  tension,  enabling  the  release  of  land  to support the development of affordable homes in the most sustainable way. Members will need to consider the interests of the Island as a whole and we must be aware that not all preferences will be accommodated.

C2

Planning  policies  are  evolving  to recognize the need to improve access to  land  with  development  potential. The  re-zoning  of  sites  to  cater specifically  for  affordable  housing development is not generally used in other  jurisdictions  such  as  the  UK, however  it  is  a  useful  policy  tool, particularly  when  land  is  in  short supply, such as is the case in Jersey.

Noted.  Agricultural  land  is  proposed  for  re- zoning only as a last resort because of the acute supply  shortage.  The  housing  mixes  on individual sites will provide family homes but vary overall. All will be zoned for affordable homes via the Housing Gateway.

C3

Having land classified with a specific use such as affordable housing should create  a  natural  cap  on  land  value which  is  significantly  below  market residential development. This is due to the long-term restrictions on the tenure of the site. There is, however, a balance to be struck between the cost of re- zoned land for affordable housing and price secured by willing landowners. This balance can usually be achieved by permitting a reasonable uplift from existing use value which arrives at a benchmark land value' (BLV).

The  Minister  for  the  Environment  will  be undertaking a viability assessment which will include an assessment of land values in Jersey, to support consideration of the introduction of a Sustainable Communities Fund for development in Jersey. This is a proposal in the draft Bridging Island  Plan.  As  there  will  be  a  number  of parallels in the research required for this and that to consider benchmark land values, the Minister will  consider  the  inclusion  of  this  in  the commissioning of the Sustainable Communities fund viability study work. In the Minister's view, it is essential that restrictions are in perpetuity, so as  to  avoid  affordable  homes  becoming unaffordable.

C4

A total of 16 sites have been identified in the Draft Bridging Island Plan as suitable  for  re-zoning  for  affordable housing. There is, however, concern that the number of sites will diminish if various  amendments  to  the  Plan  are successful in removing them from the Plan. Whilst it is acknowledged that there may be other amendments which are  also  successful  in  bringing additional  sites  forward,  there  is nonetheless a degree of risk that sites will be removed and the target delivery of  homes  will  not  be  realised  as anticipated.

This  matter  remains  under  consideration  in response  to  the  report  of  the  Independent Inspector  and  through  the  States  Assembly's consideration of the draft bridging Island Plan. Achieving  the  housing  targets  will  need  to receive primacy in the Bridging Island plan

C5

It is unclear whether the Government of Jersey will be actively pursuing the option of purchasing of housing sites in order  to  enable  and  facilitate  site assembly of viable affordable housing developments.

Both the Minister for Housing and Communities and  the  Minister  for  the  Environment  are supportive of government action in this area.

C6

Land-banking  is  an  issue  which  has existed for a number of years and is preventing the supply of new homes. Policy H5 of the Draft Bridging Island Plan  2022-25  states  that  where development  on  sites  allocated  for affordable  housing  has  not  come forward within three years of approval of the Island Plan it may be subject to compulsory purchase.

Agreed.

D1

The  £30m  annual  return  made  by Andium  Homes  to  Treasury  is  not having  a  detrimental  impact  on Andium's  ability  to:  develop affordable homes; meet their current business  objectives;  deliver  a substantial number of homes; maintain their  properties  –  all  of  which  now meet  the  Decent  Homes  Standard. However, if they were able to retain the £13m surplus, and only return £17m to Treasury  for  the  income  support payments, this would enable Andium to substantially ramp up their current projected  delivery  targets  for  new homes.

Andium Homes were able to bring 100% of the housing  stock  up  to  Decent  Homes  Standard ahead of the 10-year target and have embarked on their ambitious capital programme of 3,000 new homes by 2030 all whilst paying the annual Guarantor Return. The Minister for Treasury & Resources  has  been  willing  to  respond  with amendments  and  freezes  to  the  Return  when exceptional circumstances require.

The Panel will be aware of P.33/2013 (which approved the incorporation of Andium and the ongoing payment of the Annual Return) as well as R.15/2013 which was the business case that supported the Proposition. The States transferred the  social  housing  stock  to  Andium  for  nil proceeds  on  the  understanding  that  Andium would continue to deliver a significant annual return to the States (in line with the previous return received by the Housing Department). The Business  Case  goes  into  some  detail  on  the different  options  explored  and  the  key assumptions that approved incorporation, many of these points are still relevant today. Current Andium Executives were key proponents of the plans to incorporate Andium and supported the continuation of the Annual Return in the same format post-incorporation.

The reduction to the Guarantor Return of £13m would  represent  lost  revenue  to  the  GoJ  and would have to be replaced by either increasing tax rates or reductions to services. Ministers have no appetite to take any of these measures.

Andium Homes have recently agreed a further £75m  of  additional  loan  capacity  with  a consortium  of  local  banks  to  continue  their development programme. Therefore, if Andium Homes were able to retain £13m annually, whilst this  would  enable  them  to  repay  debt  more swiftly, it is not impacting their ability to borrow further sums to meet the target of 3,000 homes by 2030 or indeed to "ramp up" their delivery.

D2

It  is  asserted  that  in  contrast  to  the previous  grant  system  which  saw  a significant disinvestment in housing', the  90%  of  market  rent  policy  has worked  well  to  date  in  providing  a suitable  funding  mechanism  for investment  in  affordable  housing. However, it is unknown whether the Government  of  Jersey  will  actively investigate and pursue an alternative option of a capital grant system.

This is addressed in ministers' response to the recommendations made in the Scrutiny Panel's report.

D3

The  majority  of  affordable  housing providers  anticipate  making contributions to the additional supply of affordable housing over the lifespan of the Bridging Island Plan. However, there is a lack of appropriate, available sites  and  reliance  on  limited commercial  loans  is  hindering  them from doing so. The release of suitable Government-owned  sites  across  all affordable  housing  providers  would help address this issue.

The Minister for Housing and Communities has responded to this issue in R Publicly owned sites for housing.pdf (gov.je). The Minister for the

Environment is of the mind that future ministers should have access to the Regeneration Steering Group  to  influence decisions  on  the  reuse  of States owned sites where this is not necessarily the case at the moment.

D4

Jersey  Development  Company recognises the need to encourage and support  first  time  buyer  access  to homeownership. JDC currently offers a staged payment arrangement for first time buyer deposits and is also looking at addressing the high level of presale requirements  which  enable  them  to commit to construction projects, as it is their  view  that  if  that  were  to  be reduced,  there  would  be  more opportunity for JDC to focus solely on first-time buyers in relation to presales.

The  Minister  for  Housing  and  Communities welcomes this and supports the plans of SoJDC. The Minister for the Environment is of the mind that  we  should  seek  to  create  a  balance  of communities in SoJDC developments with a mix of tenures.

 D5

Purchasers  need  to  qualify  for affordable  housing  to  purchase  a shared equity property in the College Gardens Development. Provided these units are sold to another eligible first- time buyer, the Government's equity will remain in that unit. This would only not be the case in the event there are  no  eligible  buyers  from  the Housing Gateway and that a mortgage provider required the sale of a unit(s) to be sold on the open market, to enable the mortgage to be repaid. It is not envisaged that this is likely to occur.

Noted

D6

The  proportion  of  affordable  units provided  for  in  Jersey  Development Company's  residential  developments needs to factor in other requirements such as delivery of substantial public infrastructure and public realm within the  development  in  order  for development  schemes  to  stack  up financially. JDC intends to utilise the profits  from  the  residential  and commercial  components  of  each scheme  to  finance  the  public infrastructure element.

This issue is addressed in r.157-2021.pdf (gov.je) The Minister for the Environment considers that we  should  seek  to  create  a  balance  of communities in the SoJDC area with a mix of tenures.  The  issue  of  viability  of  SoJDC developments  will  be  assessed  through  the planning system. For example, there will be a public  inquiry  into  the  proposed  waterfront developments by SoJDC.

E1

There  is  a  degree  of  ambiguity regarding  whether  the  Minister  for Housing  and  Communities  has accepted  all  the  recommendations made  in  the  Housing  Policy Development Board report.

This is addressed in ministers' response to the recommendations made in the Scrutiny Panel's report.

E2

Sites  already  identified  for  new affordable  housing  take  too  long  to come  forward  for  development.  The Government  of  Jersey  has  the opportunity  to  lead  by  example  and create  a  positive  step-change  in affordable housing production.

E3

The  Island  Public  Estate  Strategy, accepted as being a high-level strategy document,  nevertheless  lacks sufficient strategic detail on a plan for the  timely  release  of  Government- owned sites for affordable housing. It identifies this as an opportunity' but setting  no  specific  objectives  for achieving this and only refers to the development  of  asset  management plans to determine how sites are used and to identify any other potential uses, such as affordable housing.

The Minister for Housing and Communities has responded to this issue in R Publicly owned sites for housing.pdf (gov.je). The Minister for the

Environment agrees with the Panel on this point.

E4

A  Political  Oversight  Group  will provide  strategic  and  political oversight  of  the  development  and delivery of the Housing Action Plan, including  progress  made  towards achieving its outcomes.

Noted.

E5

There is further scope and opportunity for  joint  ventures  between  various stakeholders in housing and property development  to  share  expertise  and deliver  mixed,  affordable  housing developments moving forward.

The Minister for Housing and Communities is providing leadership on this issue through the creation of the Strategic Housing Partnership and associated actions.

E6

Jersey  Development  Company currently has no plans to partner with any  affordable  housing  providers on future developments, although is open to the prospect of this, provided the right balance can be found with its core regeneration role.

Noted. The Minister for the Environment is of the mind that there should be an open mind on this.

E7

There is a desire to see the parishes have  a  more  supported  role  in  the delivery of affordable homes, as well as to see a more unified approach to the type of affordable housing product(s) available,  including  a  level  of consistency in the application of the qualifying criteria.

Noted. Agreed

E8

The Minister for the Environment has engaged with the parishes throughout the Draft Bridging Island Plan process "to ensure they have had an active role and contribution to planning to meet the need for affordable homes, both at strategic and local level". However, at least two parishes have suggested that their submissions of evidence of the types of homes and sites required for the parish have not been taken on board and  are  not  provided  for  in  the proposed Plan.

The process to develop the Island Plan was fully inclusive of all stated Parish views and included several  rounds  of  bilateral  meetings  with  all Constables.  The  Plan  is  required  to  meet  the island-wide  requirements  for  sustainable development and as such it is inevitable that it will not accord directly with the specific wishes of every Parish. In the final stages of the BIP further meetings with parish representatives have taken place to align these objectives if at all possible.  However,  some  will  require  clear choices by States Members.

E9

The  Minister  for  Housing  and Communities is keen for parishes to play a range of roles in the provision of affordable  homes.  The  Minister  has suggested  this  might  include: "coordinating  or  sponsoring development  of  affordable  homes; using Parish resources and networks to acquire  or  promote  land  for development; facilitating the input of local residents through surveys, Parish Assemblies  and  other  mechanisms; and providing strategic local input to policy development and plan making".

Noted;  and  the  Minister  for  the  Environment would add that the Bridging Island Plan allows for strategic planning.

F1

Fluctuating  prices  and  inflationary pressures on building and construction materials  and  disruption  to  supply chains may inevitably have an adverse impact  on  pushing  up  higher  build costs  and  ultimately  the  delivery  of new housing developments.

Noted

F2

The Government of Jersey is seeking to  address  the  issue  of  skills development and concerns of capacity within  the  construction  sector  by working with industry partners as part of the newly formed Strategic Housing Partnership.  Currently,  Government supports  skills  development  through provision of further education.

Noted

F3

The construction sectors in both the UK and Jersey are becoming stretched to  capacity  and  increases  in  raw materials will be contributing to higher build costs, which in turn will have an effect on the viability of schemes but also the cost of new homes. There are shortages in some building materials and  whilst  it  is  hoped  this  will  be temporary,  pressures  on  labour  and materials  will  be  a  considerable ongoing challenge for the construction sector which will need to be monitored closely over the coming months / year.

Noted

F4

There is a potential and credible risk that Government resources and other competing project priorities, such as the  new  hospital  and  office modernisation project will hinder the timely release of Government-owned sites and, consequently, the delivery of affordable housing targets.

There  is  an  on-going  need  to  manage  the competing demands for space to meet a variety of public service requirements, all of strategic importance. This coordination is provided by the Estates Strategy. A consideration of innovative construction  techniques,  materials  and exploitation  of  brownfield  sites  will  also contribute to mitigating this risk.

F5

There is an apparent disparity between the experience of Jersey Development Company, who do not appear to have experienced significant delays in the planning application process. This is in stark  contrast  to  the  experiences described by Andium Homes and the Jersey Construction Council who both have indicated that the planning team is  considerably  under-resourced, causing  major  issues  with  delays  to approval of planning applications.

The Minister for the Environment welcomes the additional  investment  into  IHE  Regulation, including  the  Development  Control  function, provided  in  the  Government  Plan  2022-25, which will significantly support improvements in the  throughput  of  planning  applications. However, delays should not be attributed only to resource limitation. It is essential the planning system  continues  to  challenge  robustly  any planning applications which do not meet Island Plan policies, result in overdevelopment, or fail to  provide  amenity  space  and  public  realm improvements  whether  they  be  by  private  or public applicants, such as Andium.

F6

There is uncertainty as to whether the Government  of  Jersey  will  utilise outsourcing options for the production of  development  briefs  in  order  to temporarily  address  resource constraints within the Planning team. Instead,  it  is  commented  that  this option will be kept under review'.

Noted; development briefs are well advanced.

F7

An Interim Head of Strategic Housing and Regeneration has been appointed in  September  2021.  It  is  anticipated that ongoing recruitment for the newly formed  Strategic  Housing  and Regeneration Team will be sufficient to meet requirements of leading and co-ordinating strategic housing policy initiatives  within  Government, although the intended size of the team is currently unknown.

Noted.

F8

Andium  Homes  is  actively  pursuing various  innovative  forms  of  modern methods  of  construction  by  trialling these on various development sites. To date,  they  have  successfully  trialled Insulated Concrete Forms and Hadley Steel Frames and are looking to trial other  types  on  future,  upcoming developments.

Noted

F9

Modern  Methods  of  Construction could  be  a  useful  tool  to  boost  the supply of homes in Jersey. The main barrier is shipping and transportation costs.  It  is  Jersey  Construction Council's  view  that  developing  new supply chains to increase competition would enable MMC at larger scale, as would on-island assembly facilities for bathroom/kitchen pod production.

The  Minister  for  Housing  and  Communities continues to lead research and consideration in this  area  in  order  to  inform  future  policy development. The Minister for the Environment would  note  that  this  needs  to  be  done  in partnership with the Regulation directorate of IHE to ensure new methods comply with current requirements for the quality of homes.

F10

A  Modern  Methods  of  Construction Political  Working  Group  has  been established  by  the  Minister  for Housing and Communities to prove the case for the opportunities provided by new, innovative technologies.

Noted. See F9 above.

G1

It is the view of some stakeholders that current planning policy is not fit for purpose  and  the  proposed  new Bridging  Island  Plan  will  not adequately address some of the current longstanding policy issues.

These are considered to be minority views and, as such, not an accurate reflection of planning policy.  The  appropriateness  of  the  Bridging Island  Plan  will  be  determined  by  the  States Assembly, based on robust public consultation and the report of the Independent Inspector

G2

Planning  requirements  for  parking provision does not appear to be aligned with  Sustainable  Transport  Policy where  the  aim  is  to  reduce  vehicle usage  over  time.  In  addition, developers,  such  as  Andium  Homes have clear evidence which shows that current  provisions  are  often unnecessary according to the demand, particularly in town. This is an issue given  that  requirements  for  high parking ratios can make a development scheme unviable.

The draft bridging Island Plan responds fully to the Sustainable Transport Policy and proposes a range of new policy, including new approaches to parking standards.

G3

On  the  whole,  developers  do  not appear to be able to access an adequate level  of  planning  pre-application advice  despite  there  being  a willingness  to  pay  an  extra  fee  to receive a timelier service.

There have been limited resources in IHE which have most recently been addressed by an increase in  funding  proposed  in  the  most  recent Government Plan. Historic issues were a result of redeployment  as  part  of  the  Government's response  to  the  pandemic  and  organisational changes. The aspiration to levy a charge for a pre-application  service  is  understood  and accepted. It does, however, require a change to the Planning and Building Law, which can be included within the next amendment.

G4

The Draft Bridging Island Plan 2022- 25 does not propose setting a policy requirement  for  a  percentage  of affordable homes on new development sites. However, it is suggested that this could be a policy proposal in the next longer-term Island Plan. The aspiration and focus of the shorter-term Bridging Island  Plan  is  on  delivering Government-owned  sites  for affordable housing.

Accepted but the inspector report has supported the principle.

This is a topic under consideration as part of the Bridging Island Plan process as it is touched upon by States Members amendments.

G5

The Draft Bridging Island Plan 2022- 25 proposes the use of a Sustainable Communities Fund in preference to a policy requiring a certain percentage of affordable  homes  on  new developments. The rationale provided for this is due to construction sector limitations and other wider ambitions of the Island Plan, such as increasing standards  on  thermal  efficiency  and amenity space etc. It was not deemed viable to implement both policies at the same time.

Noted. See above G4. It is accepted that the SCF and Percentage of affordable homes policy need to be considered in tandem. This matter is being actively  considered  by  the  Minister  for  the Environment.

G6

Andium  Homes  would  welcome planning  policy  setting  out requirements  for  a  proportion  of affordable  homes  on  new  housing developments,  however  for  it  to  be workable, they suggest that a suitable mechanism would need to be put in place to ensure that the proportion of affordable homes are sold to those who need them and so there is no scope for profiteering'. In addition, the sales of those homes would need to ensure that they remain as an affordable unit for future onward sales.

Agreed; please see responses to G4 and G5.

G7

The  Jersey  Construction  Council consider  that  a  policy  setting  out  a "must provide" requirement to deliver a proportion of affordable homes on all new  residential  development  would have a detrimental impact on private sector development in the island and it would favour an approach that more closely aligns the needs of the public with  the  resources  of  private  sector developers and landowners.

Noted.  The  position  of  the  JCC  was  not supported by the Inspectors when examining the Bridging Island Plan. However, it is accepted such policy would need to be adopted cautiously and progressively subject to careful monitoring to ensure the market was not chocked off. See G4-6

G8

The Draft Bridging Island Plan states a viability  case  assessment  should  be provided  by  developers  where  it  is considered  that  conforming  to Passivhaus  standards  will  render  a development  unviable  and  that  a reasoned  justification  must  be provided.  If  accepted,  the  developer will be required to demonstrate how the building has been designed, as far as practicable, to achieve the highest possible  standard  towards  reaching Passivhaus standard.

Noted. This is under review, and it is likely that there will be an amendment to the draft Bridging Island Plan.

G9

Andium  Homes  has  presented evidence to the Draft Bridging Island Plan 2022-25 Examination in Public process which outlines the concerns of the  local  construction  industry  in relation to the proposed introduction of Passivhaus  standards.  The  concerns raised confirmed Andium's view that the introduction of Passivhaus would be  premature  and  could  have significant consequences which would adversely  impact  on  the  supply  and delivery of homes during the period 2022-26 and beyond.

Noted. Discussions with Andium Homes on this matter continue; see G8.

G10

Jersey  Development  Company  are attempting to ensure that Passivhaus accreditation is achieved on the South Hill development, although it is not a certainty. It is unclear whether Policy ME2  of  the  Draft  Island  Plan,  if adopted, would prescribe that both the Waterfront  and  South  Hill developments will be required to meet Passivhaus standards as the land will no longer be Government-owned and the developments are not exclusively providing affordable homes.

The  Minister  for  Housing  and  Communities welcomes this and supports the plans of SoJDC; see G8.

G11

Expert advisor's, ARK, consider the Passivhaus  standard  for  achieving energy  efficiency  and  low  carbon emissions  is  "very  prescriptive" approach  relying  heavily  on airtightness of buildings and which not all occupants are comfortable with the home environment it creates. Instead, ARK suggests other approaches such as the Scott ish Government's Energy Efficiency  Standards  in  Social Housing 2 (EESSH2) standard which offers more flexibility in its approach.

Noted. This matter has been considered in the report of the Independent Inspector, and remains under consideration by the Assembly, who will debate the draft Bridging Island Plan policies, and the detail of policies therein in March 2022. It is however stressed that the policy proposed within the draft Plan affords sufficient flexibility to  accept  a  lesser  standard,  where  this  is appropriate.  Work  is  underway  to  ensure guidance is available to support developers in applying Passivhaus standard, which helpfully has a number of design and specification tools available,  making  it  easier  to  use  than  many lesser-known standards. See G8.

H1

Lack of decent, affordable housing is a significant  issue  for  attracting  and retaining  key  workers  on  island. Andium  Homes  consider  the  swift release of suitable public- owned sites for key worker accommodation to be opportunities which cannot be missed. The  Government  of  Jersey  will  be carrying out further work in early 2022 to define key worker status in relation to housing and the various conditions which will apply regarding residential status and employment related support or subsidy. The aim is to support the delivery of 25 key workers homes each year until 2025.

Noted.

H2

A clear and consistent policy on net- inward  migration  and  population control  is  integral  to  accurately estimating  the  supply  of  homes required, and in ensuring that numbers of net-inward migration do not outstrip the  delivery  of  new  homes.  The planned assumption of 800 net-inward migration  each  year  is  considerably less than what has been permitted in previous  years  and  therefore  the successful delivery of the right number of  homes  will  be  contingent  on  the projected assumptions being accurate and strictly enforced.

 Agreed. The BIP has, by necessity, had to adopt a  planning  assumption  of  an  increase  of  800 persons annually, comprising 100 persons due to natural  growth  and  700  due  to  migration. Regrettably, since the assumption was adopted no  data  on  actual  migration  is  available  to validate the reduced number. Once the outcome of the census is received, government will be in a position to improve the methods with which to plan for adequate delivery of homes.

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

1

RECOMMENDATION  A1:  The Objective  Assessment  of  Housing Need (OAHN) which underpins the Draft Bridging Island Plan, should be built  on  and  updated  to  develop  a model  to  assess  housing  need  and demand.  The  purpose  of  this  is  to provide a robust, shared and agreed evidence base for housing policy and land use planning. The model should include a methodology for assessing housing  affordability,  critical  to establishing  the  degree  to  which market housing offers an affordable option to residents. Once a measure of affordability is established, it will help to  determine  whether  demand  for housing  is  being  met  within  the market and the extent of unmet need. This  in  turn  enables  the  required housing  supply  target  to  be  set including:  the  type  of  housing,  the tenure that should be provided and the amount  of  affordable  housing required.  This  robust  methodology would then form a consistent basis for regular (at least every 5 years) reviews of housing need and demand.

It  is  recognised  that  the  OAHN methodology can be expanded and strengthened. The Assessment will be reviewed ahead of the next Island Plan, drawing on the methodology and  insights  from  the  current housing  market  review, commissioned  by  Minister  for Housing  and  Communities,  and drawing  on  existing  methods  and tools developed by Statistics Jersey as  well  as  new  capabilities  for market  analysis  that  will  be developed in the Strategic Housing and Regeneration Team.

Accept

2024

2

RECOMMENDATION  A2:  The Minister  for  Housing  and Communities  should,  by  January 2022, expedite amendments to policy guidelines for determining eligibility for social rent and affordable purchase properties. The outcomes of doing so should be used to review the mix of tenure  for  the  affordable  sites proposed  within  the  Draft  Bridging Island Plan to ensure that the mix is reflective of actual housing need.

The  tenure  split  for  designated affordable housing sites is presently under  consideration  through  the Island Plan review process, where the  Minister  for  the  Environment has asked the independent planning inspectors  to  consider  potential policy  changes  to  how  tenure  is allocated  on  affordable  housing sites.  The  Minister  for  the Environment  therefore  wishes  to reserve  his  position  until  the planning  inspectors'  report  is received.

Accept

Q1 2022

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

The  Minister  for  Housing  and Communities set out new eligibility criteria  for  social  rent  accessed through the Housing Gateway in his Fair Rents Plan. There are currently no  proposals  to  amend  eligibility guidelines  for  assisted  purchase  - which has only recently published new eligibility criteria.

3

RECOMMENDATION  A3:  The Minister  for  Housing  and Communities  should  work  with  the Minister  for  the  Environment  to ensure  that  the  policies  contained within the Draft Bridging Island Plan are flexible to the types of homes built on the proposed sites and with suitable

right-sizing  options  in  mind.  This should  be  done  as  part  of  the Examination in Public process of the Draft  Island  Plan  and  so  that  any identified issues with certain sites can be addressed prior to approval of the Island Plan in 2022.

Both  ministers  are  committed  to

better  joining  up  housing  and

planning policy,  as set out  in  the

Creating Better Homes plan (Action

5E). This includes working together,

as set out in the bridging Island Plan,

on the appropriate mixture of homes   for rezoned sites. This will include

consideration  of  the  report  of  the

Independent Inspector.

Accept

2022

4

RECOMMENDATION  A4:  The Minister  for  Housing  and Communities  should  work  with  the Minister  for  the  Environment  to formulate  a  suitable  contingency measure, should it be determined that the sites zoned for affordable housing will not deliver the required type and number  of  properties  suitable  for right-sizing. Consideration should be given to a reserve list of zoned sites for  housing  and/or  Supplementary Planning  Guidance  which  would facilitate the development of homes where it can be demonstrated there is a need for suitable right-sizing options which cannot be met from the agreed

This  matter  is  being  considered through the examination in public process.  The  Minister  for  the Environment  will  respond  upon receipt  of  the  inspectors'  report, which will include consideration of those sites the Minister has already indicated he may support if the sites set out in the bridging Island Plan are  not  supported  by  the  States Assembly. The Minister recognises the  importance  of  right-sizing opportunities  within  the  housing mix.

The  Minister  for  Housing  and Communities is already working to

Under conside ration

End 2022

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

list of sites. This should be carried out without delay and in consultation with the Comité des Connétable s, Andium Homes and other housing providers.

develop an appropriate right-sizing policy, which will consider the level of  demand  and  what  may  be  an appropriate response to ensure that identified needs can be met.

5

RECOMMENDATION A5: In order to effectively facilitate a downsizing / right-sizing'  policy,  the  housing aspirations of older people need to be understood,  including  what  specific features  of  new  accommodation would  motivate  them  to  move  and what incentives they would need. The Minister  for  Housing  and Communities  should  ensure  that  a right-sizing'  policy  has  clear  and measurable objectives and should be specific in its targeting to ensure that applicants meet the requirements of the Housing Gateway.

The  Minister  for  Housing  and Communities is already working to develop an appropriate right-sizing policy, which will consider the level of  demand  and  what  may  be  an appropriate response to ensure that identified needs can be met.

Accept

End 2022

6

RECOMMENDATION  A6:  The Minister  for  Housing  and Communities should ensure that, on a needs basis, there should be financial incentives  for  elderly  people  to encourage  them  to  downsize' whether to buy or rent, as often they don't have the financial means that will enable them to move. This should not  affect  their  rights  to  the  Long- Term  Care  scheme.  Alternative property  needs  to  be  suitable.  As people are living longer, so they can remain  independent,  the  properties need to be affordable, safe, suitably sized,  near  shops/community venues/bus stops. Supplying quality, safe  and  affordable  housing  to  the elderly  will  free  up  and  make available  their  property  to  young families. This should be implemented before the end of 2022.

The  draft  Bridging  Island  Plan, presented  by  the  Minister  for  the Environment,  seeks  to  ensure development is provided in the most sustainable locations, near to local services, and is designed in such a way  to  meet  the  needs  of  the community.

The  Minister  for  Housing  and Communities is already working to develop an appropriate right-sizing policy, which will consider the level of  demand  and  what  may  be  an appropriate response to ensure that identified needs can be met.

Accept

End 2022

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

7

RECOMMENDATION  A7:  The Minister  for  the  Housing  and Communities should ensure that the housing  needs  of  some  younger cohorts (such as those with learning disabilities,  who  are  homeless  or young care leavers) with specialised housing requirements are understood more fully. This should lead to the setting  of  specific  targets  for appropriate types of housing based on up-to-date information on current and forecast need. This should be carried out before the end of 2022.

The Minister agrees that the needs for  these  cohorts  should  be understood more fully and will work to ensure there is adequate baseline data.  To  inform  the  provision  of Housing types, etc is in line with identified needs.

Accept

Q1 2023

8

RECOMMENDATION  A8:  The Minister  for  Housing  and Communities should ensure that data pertaining to the types of individuals accessing the Housing Advice Service is  suitably,  and  anonymously, captured  in  order  to  help  inform existing and future housing need (in conjunction  with  other  modelling such  as  the  OAHN).  The  Minister should work in collaboration with the Minister  for  the  Environment  to ensure  that  both  existing  and emerging housing need is promoted through planning policy and to help inform  build  programmes  of affordable homes over the lifespan of the Bridging Island Plan and beyond.

The  Housing  Advice  Service  was introduced  during  2021  and  it continues to develop and expand the services provided. Usage statistics and  case  studies  will  be  used  to support both this development and more general planning policy.

Accept

Q4 2022

9

RECOMMENDATION  A9:  The Minister  for  Housing  and Communities  should  ensure  that qualitative research is carried out to capture  and  identify  and  changing aspirations  and  expectations  in housing  demand.  This  should  be incorporated into other workstreams contained within the Housing Action Plan with a suitable timeline provided.

The  Minister  for  Housing  and Communities  accepts  the  need  to understand housing need, using both qualitative and quantitative data.

This will be done by drawing on existing  methods  and  tools developed  by  Statistics  Jersey,  as well as the new capability for market analysis that will be developed in the

Accept

Q1 2023

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

Strategic Housing and Regeneration Team.

The  Minister  has  already  liaised with each Connétable to ensure that the understanding of housing need held by Parishes is considered. This process will continue.

10

RECOMMENDATION  A10:  The Council of Ministers should consider the  appropriate  use  of  fiscal  levers such as tax incentives / disincentives to discourage properties lying vacant in  the  medium  to  long  term.  This should  be  considered  and  reported back to the States Assembly before the end of 2022.

The  Minister  for  Housing  and Communities  continues  to  discuss these  matters  with  colleague ministers. The outcome report of the 2021 Census will provide more data in relation to empty homes, which will  help  inform  the  design  of interventions  supported  with available funds that are provided in the Government Plan 2020-23. Any new fiscal levers would be expected to  be  brought  forward  in  the Government Plan.

Under conside ration

Q4 2023

RECOMMENDATION  B1:  The Council  of  Ministers  should  report back  to  the  States  Assembly  by January 2022 with a further update on progress  on housing policy  actions, including  the  possibility  of  re- establishing the rent tribunal process with the aim of providing some level of protection and recourse for tenants against  excessive  rent  rises  in  the private  sector  whilst  further protection  measures  are  researched and considered.

A  commitment  to  re-establish  the Rent Control Tribunal, is provided in the Fair Rents Plan.

The  Minister  for  Housing  and Communities has provided regular updates on delivery of his Creating Better Homes action plan, including in R.157/2021.

Accept

Complete

RECOMMENDATION  B2:  The Minister  for  Housing  and Communities  should,  by  January 2022, revise the current definition of affordable housing to make provision for relating this to

income levels.

The eligibility criteria for social rent and  assisted  purchase  already reference income levels. This is set out in the definition of affordable housing.

Accept

Complete

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

RECOMMENDATION B3: As part of  the  proposed  social  rents  policy review, the impact on tenants of their rents being set at, or increasing to 90% of market rent should be investigated. The  review  should  also  assess  and report on, prior to the end of 2021, the ability of tenants to meet their living costs,  the  role  played  by  income support and whether rents set at 90% of  market  rent  discourages  people from  taking  up  employment opportunities.

The  Minister  for  Housing  and Communities  Fair  Rents  Plan includes the commitment to a new policy that sets social rents at 80% of market plan.

Accept

Complete

RECOMMENDATION  B4:  The Minister  for  Housing  and Communities  should  ensure  that  as part  of  the  commissioned  research into  suitable  affordable homeownership  products,  the affordability  of  low-cost  home ownership products is assessed in line with  recommendation  two  of  this report. This can then be used to define the most appropriate low-cost home ownership  product  and  whether  the assisted purchase scheme needs to be updated.

This is already being addressed as part  of  a  housing  market  review commissioned by the Minister for Housing and Communities in line with action 4a in the Creating Better Homes action plan.

Accept

End 2022

RECOMMENDATION  B5:  The Minister  for  Housing  and Communities should, as part of the consideration  of  suitable  affordable home  ownership  products,  consider varying the equity

level being sold to target particular groups,  such  as  key  workers  or specific income levels.

This is already being addressed as part  of  a  housing  market  review commissioned by the Minister for Housing and Communities in line with action 4a in the Creating Better Homes action plan.

Accept

End 2022

RECOMMENDATION  B6:  The Minister  for  Housing  and Communities  should  ensure  that investigation into the impact of buy- to-let  properties  on  housing affordability  and  any  suitable

The  Minister  for  Housing  and Communities  continues  to  lead discussions on the impact of buy-to- let matters with colleague ministers.

Accept

Q1 2023

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

measures to restrict and/or control this purchase  type,  where  and  if appropriate to do so, should be a focus for  the  newly  created  Strategic Housing and Regeneration Team and that an update should be provided to the States Assembly on the outcome of this work by the end

of Q1 2022.

Understanding the optimum role of buy-to-let  in  the  Jersey  housing market will form part of work for the new  market  analysis  capability developed in the Strategic Housing and Regeneration Team. Q2 2022 is a more realistic timescale, given the need  to  fully  explore  the consequences of any intervention.

RECOMMENDATION  B7:  The Council  of  Ministers  should  ensure that  an  assessment  is  carried  out, before the end of Q2 2022, of the scale and  impact  the  relaxation  of  the criteria  contained  within  paragraph 121  of  the  Residential  and Employment Status policy guidance (relating  to  ability  for  High-Net- Worth  individuals  moving  to  the island to be able to own their own main  residence  and  additional property for rental investment under certain criteria) has had on housing market  conditions.  As  part  of  this assessment, consideration should be given  to  revising  the  guidance  to ensure that suitable policy levers are in place to prevent the possibility of this having an inflationary effect on rents and property prices.

Paragraph 121 of the guidance was amended  in  2018  to  permit  the limited ability of 2(1)(e) residents to purchase properties for renting.

Since  that  time,  zero  permissions have  been  granted  for  rental properties  in  relation  to  those changes.

2(1)(e) residents have therefore not been  provided  permission  to purchase properties for rental.

Nevertheless,  the  policies  remain under ongoing review, including in relation to the ability of 2(1)(e)s to transact in the housing market and their overall impact on the housing market.

Under conside ration

RECOMMENDATION  B8:  The Council of Ministers should explore further the possibility of whether the sale  of  existing  share  transfer properties  can  be  restricted.  This should be investigated and reported back to the States Assembly before the end of Q1 2022.

The  Minister  for  Housing  and Communities  continues  to  lead discussions on the impact of buy-to- let matters with colleague ministers.

Understanding the optimum role of buy-to-let  in  the  Jersey  housing market will form part of work for the new  market  analysis  capability developed in the Strategic Housing and Regeneration Team. Q2 2022 is a more realistic timescale, given the

Under conside ration

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

need  to  fully  explore  the consequences of any intervention.

RECOMMENDATION  C1:  The Minister for the Environment should consider other process improvements to expedite planning applications for housing  schemes,  especially affordable

housing.  This  should  include  a formally  agreed  pre-application process with appropriately set fees for applicants, in addition to other fast- tracking initiatives such as better use of permitted development rights and dedicated  planning  team  members. The Minister should feedback to the Panel before the end of January 2022 regarding  which  options  have  been considered and will be taken forward with  clear  timescales  of implementation provided.

The IHE (Regulation) Department's operating  model  already  provides for  a  new  role  (Senior  Planner  - Special Projects) to deal with large schemes, funded out of application fees.  An  appointment  has  already been made, with a start date of mid- 2022.   Pre-application  advice  is currently free and will require a Law change  to  allow  a  charge  to  be levied. A change in the level of exemptions will require a change to the  General  Development  Order, which  must  include  a  significant public consultation exercise. Both of these  actions  will  take  12-18 months.

Under conside ration

Mid 2023

RECOMMENDATION  C2:  The Council  of  Ministers  should  ensure that some follow-up study is carried out, with input from an experienced RICS  accredited  Jersey  valuation practice before the end of Q2 2022, on establishing  appropriate  benchmark land value for sites zoned, or in some other  way  restricted,  for  affordable housing  development.  The  output from this work should help to manage expectations  on  land  price  for  all relevant  parties  and  support  the development economics of affordable housing schemes.

The Minister for the Environment will  be  undertaking  a  viability assessment  which  will  require  an assessment of land values in Jersey, to  support  consideration  of  the introduction  of  a  Sustainable Communities Fund for development in Jersey. This is a proposal in the draft Bridging Island Plan. As there will be a number of parallels in the research required for this and that to consider benchmark land values, the Minister will consider the inclusion of this in the commissioning of the Sustainable  Communities  fund viability  study  work.  It  is  not possible to develop this work in the timescales suggested, given existing priorities and available resources.

Under conside ration

Q1 2024

RECOMMENDATION  C3:  The Council of Ministers should outline whether it is the intention to seek the purchase of sites for site assembly of

Currently, site assembly through the purchase  of  private  sites  is  not actively considered. This is because:

Accept

End 2023

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

viable  affordable  housing developments.

This  should  be  outlined  in  the Ministerial Response to this scrutiny report,  along  with  i)  a  rationale  of why, if it is not the intention; or ii) an outline timeframe if it is the intention.

1  –  both  the  Minsters  for Environment  and  Housing  and Communities,  working  with  the Minister  for  Infrastructure,  have prioritised the provision of publicly owned sites for housing. Ministers, in  November,  committed  to  bring forward land to accommodate over 800 units over the next 5 years on a range of government owned sites.

2 – currently, no funding is made available for the acquisition of sites in this way.

However, both the Minister for the Environment  and  the  Minister  for Housing  and  Communities,  to varying degrees, are keen to explore opportunities  to  re-introduce  the means  for  site  acquisition  in  this way and will continue to explore the issue using available resources.

RECOMMENDATION  C4:  The Minister  of  Housing  and Communities  should  advocate  a strong role for what is described as housing  enabling'  within  the function of the Strategic Housing and Regeneration Team. Active enabling will include a range of Government- led  initiatives  covered  elsewhere  in our  recommendations;  however,  it also  describes  a  practical  level  of support for delivery partners to bring schemes  forward  and  an  energetic programme  management  role.  This will  identify  early  blockages  to progress  with  schemes  and  co- ordinate

action across Government and with partners to get schemes back on track.

This is intended as a key function of the  Strategic  Housing  and Regeneration Team. The creation of the Strategic Housing Partnership is an example of steps being taken to develop the systems to work in this way.

Accept

Complete

Recommendations

Response

Accept/ Reject/

Under Consider ation

Target date of action/ completion

RECOMMENDATION  C5:  The Council of Ministers should seek to release  identified  sites  in  its ownership  for  affordable  housing schemes before the end of Q2 2022. Consideration should be given to how disposal processes can be sped up in return for provider commitments on building  out  sites  within  an  agreed period.

Ministers, in November, committed to  bring  forward  land  to accommodate over 800 units over the  next  5  years  on  a  range  of government owned sites.

Work  is  underway,  led  by  the Minister  for  Infrastructure  and  in line  with  the  Estates  Strategy,  to improve disposal processes.

Accept

Complete

RECOMMENDATION  C6:  The Council  of  Ministers  should  ensure that  identification  and  release  of suitable  Government-owned  sites should be made available across all affordable  housing  providers  where appropriate. Consultation should take place across all the affordable housing providers  by  January  2022  to understand  their  financial  delivery models,  varying  affordable  housing products  and  required  site characteristics  to  enable  informed decisions to be made in relation to meeting the development needs of the provider  as  well  as  the  best,  most efficient  use  of  the  sites  following their release.

Housing Trusts are engaged on an on-going basis, with direct access to Minister  for  Housing  and Communities  and  also  though  the Strategic Housing Partnership.

The  Strategic  Housing  and Regeneration team will support the Minister  to  maintain  these relationships  and  ensure  other housing  trusts  can  play  their appropriate  roles.  The  suggested analysis is not a pre-curser to this engagement, and it is not possible to develop this work in the timescales suggested, given existing priorities and available resources.

Q1 2023

RECOMMENDATION  C7:  The Council of Ministers should consider whether,  for  some  of  the  sites earmarked  for  affordable  housing, Government  could  enter  early disposal deals with