Y Pwyllgor Llywodraeth Leol a Thai

Local Government and Housing Committee


Aelodau'r Pwyllgor a oedd yn bresennol

Committee Members in Attendance

Altaf Hussain
Carolyn Thomas Yn dirprwyo ar ran Lee Waters
Substitute for Lee Waters
James Evans
John Griffiths Cadeirydd y Pwyllgor
Committee Chair
Sian Gwenllian

Y rhai eraill a oedd yn bresennol

Others in Attendance

Alicja Zalesinska Prif Weithredwr, Tai Pawb
Chief Executive, Tai Pawb
Avril Roberts Uwch-gynghorydd Polisi Eiddo a Busnes, Cymdeithas Tir a Busnesau Cefn Gwlad
Senior Property and Business Policy Adviser, Country Land and Business Association
Ben Murphy Cyfarwyddwr Ystadau, Dugiaeth Cernyw
Estates Director, Duchy of Cornwall
Casey Edwards Rheolwr Prosiect, Cwmpas
Project Manager, Cwmpas
Craig O’Connor Pennaeth Creu Lleoedd, Cymdeithas Swyddogion Cynllunio Cymru
Head of Placemaking, Planning Officers Society Wales
Debbie Thomas Pennaeth Polisi a Chyfathrebu—Cymru, Crisis
Head of Policy and Communications—Wales, Crisis
Elizabeth Taylor Swyddog Ymgysylltu a Pholisi,TPAS Cymru
Engagement and Policy Officer, TPAS Cymru
Sam Rees Uwch-swyddog Materion Cyhoeddus—Cymru, Sefydliad Brenhinol y Syrfewyr Siartredig
Senior Public Affairs Officer—Wales, Royal Institution of Chartered Surveyors

Swyddogion y Senedd a oedd yn bresennol

Senedd Officials in Attendance

Angharad Era Dirprwy Glerc
Deputy Clerk
Jennie Bibbings Ymchwilydd
Rachael Davies Ail Glerc
Second Clerk

Cofnodir y trafodion yn yr iaith y llefarwyd hwy ynddi yn y pwyllgor. Yn ogystal, cynhwysir trawsgrifiad o’r cyfieithu ar y pryd. Lle mae cyfranwyr wedi darparu cywiriadau i’w tystiolaeth, nodir y rheini yn y trawsgrifiad.

The proceedings are reported in the language in which they were spoken in the committee. In addition, a transcription of the simultaneous interpretation is included. Where contributors have supplied corrections to their evidence, these are noted in the transcript.

Cyfarfu’r pwyllgor yn y Senedd a thrwy gynhadledd fideo.

Dechreuodd y cyfarfod am 09:15.

The committee met in the Senedd and by video-conference.

The meeting began at 09:15.

1. Cyflwyniad, ymddiheuriadau, dirprwyon a datgan buddiannau
1. Introductions, apologies, substitutions and declarations of interest

Welcome, everyone, to this meeting of the Local Government and Housing Committee. I particularly wish to welcome Siân Gwenllian MS to her first meeting as a member of the committee. Croeso, Siân. We've received apologies from committee member Lee Waters MS, and Carolyn Thomas is here as a substitute. Croeso, Carolyn. As we've previously noted as a committee, our committee member Sarah Murphy has recused herself from all committee business following her appointment as a Minister in the Welsh Government. Sarah remains a member of the committee until a replacement is elected. The meeting is being held in hybrid format. Public items of the meeting are being broadcast live on Senedd.tv and a Record of Proceedings will be published as usual. The meeting is bilingual and simultaneous translation is available. Are there any declarations of interest from committee members? There are not.

2. Cyflenwad tai cymdeithasol: Sesiwn dystiolaeth 6
2. Social housing supply: Evidence session 6

We will move on to item 2 on our agenda today, social housing supply and our sixth evidence session. I'm very pleased to welcome, joining us here in person, Sam Rees, senior public affairs officer for Wales for the Royal Institution of Chartered Surveyors, and joining us virtually, Craig O'Connor, head of placemaking for Planning Officers Society Wales. Welcome, both. Thanks for coming in to give evidence to the committee this morning. I will begin with a couple of questions. Firstly, an overview question: how would you summarise your view of the major challenges we face in Wales in attempting to increase social housing supply? Who would like to begin?

I'll go first. I think, firstly, it's important to recognise that the challenge of delivering social housing in Wales is not exclusively for the social housing sector. We're having identical conversations across the private rented sector and the owner-occupier sector as well. I think it's pretty well documented, some of the challenges: planning resource, nutrient neutrality, labour, materials, cost of inflation. It's a huge spectrum of issues and it's not exclusively for Wales either. Obviously, in Wales, we've got housing targets set at a UK level as well. There are varying degrees of housing targets—bluntly, none of which have actually been met. I think, actually, at the UK level, we're talking of 300,000 new homes a year—not since the 1960s has that target actually been met. In Wales, there's a 20,000 target—it's closer to being met in terms of actually delivering new properties.

On the broader challenges of delivering social homes, in terms of what I was saying about the more recognised challenges, one of the important ones, which is quite distinct to social housing, however, is funding. A lot of social housing providers we've been speaking to, along with the varying other challenges faced across the housing sector, have actually been struggling with funding for new homes. Given the challenges facing their existing stock portfolio—meeting the Welsh housing quality standard, building safety, energy efficiency—it means that priority of delivering new homes is almost on the back foot now because they have to prioritise their existing stock to meet current legislation.

Good morning, committee. Sam has mentioned quite a lot of stuff there, and I think it's probably right to emphasise some of those elements from a planning authority point of view. There are certainly difficulties in terms of some of the constraints. Particularly over the last few years, phosphates has had a significant impact, particularly in rural areas. The nine special area of conservation river catchments across Wales have now got higher levels of protection, which is right and appropriate. However, the levels of mitigation and solutions to enable development to happen sustainably haven't been forthcoming. We had the fourth summit recently. We are getting to a position, working with the agricultural sector, Welsh Water and Natural Resources Wales, where the planning is starting to be allowed, and we can allow development sustainably, but certainly in our rural communities, phosphates has been a significant issue.

The other issue is flooding in our more coastal areas. We've been working with Welsh Government colleagues in terms of developing the new technical advice note 15 for flooding, which has stalled over the last number of years. I think there's a lack of clarity in terms of where that policy is going. Hopefully, that policy will be released at the end of the year, and that will enable us to have clarity in terms of placemaking and in terms of allowing plans to go ahead and us to be making informed decisions. In terms of that clarity of place and getting that policy position right, I think that's what local planning authorities are seeking.

In terms of replacement local development plans, there's been significant improvements, I think, in terms of this set of development plans, compared to previous development plans—they're much more now based on viability. Viability is a massive issue in terms of delivering affordable housing, and local planning authorities being able to negotiate with developers to provide that affordable housing. On the last set of plans, viability wasn't taken into account as much. In the new set of replacement plans, that won't be the issue; every site will be viability assessed before it's allocated. So, that will be a massive positive. But over the last 10 years, I would say, that is probably an issue—when sites actually look to gain planning consent, is the viability there, has that been significantly looked at. A lot of times, a lot of authorities haven't hit their affordable housing targets on some of the strategic sites. As I say, hopefully that will change in the future.

One thing with regard to replacement local development plans I would suggest is the timeline. I think the timeline is about three and a half years to deliver a plan. I think all authorities are slipping on that, and that is because it is onerous. There is a lot of work to be done as part of that, and I would wonder whether there are ways we could simplify that and make it more streamlined, to deliver plans. We definitely need a planning-led system in Wales for communities. However, can we look at making that more streamlined? Can it come forward quicker, to enable social housing to be delivered at a faster rate?

In terms of delivery, one of the other aspects to look at here is also the funding models for affordable housing—so, can social housing grant be used in different ways. In terms of the funding model for social housing, it relates to above and beyond section 106 requirements. I would make a suggestion that maybe we should be looking at whether, if a site is considered to be unviable, social housing grant can be used to prop it up to the policy provision within the section 106 requirements. I've had conversations with housing officers in the Welsh Government who I know are considering that at the moment, but I would advocate that that is something that certainly needs to be done—looking at the terms and conditions of funding models.

Sam also mentioned planning resources—that certainly is an issue, and I know that is also being looked at. As Planning Officers Society Wales, we've been lobbying the Minister, Julie James, for increases to planning fees, so that we can invest in resources and invest in getting planning officers, educating people, working with the Royal Town Planning Institute to look at ways that we can get new, young planners into the system, because I think resources is a massive issue. And when I say 'resources', I'm not just talking about planning officers. Planning is quite holistic and we need to make sure that we have the right ecologists, highway officers, drainage officers. When we talk about planning, it's that whole wide range of specialisms that we need to ensure is robust to deliver sustainable development across Wales, and deliver, obviously, the much-needed affordable housing provision.

I would suggest they're the main constraints that have happened over the last few years, but there are, obviously, a lot of positive stories as well. I know that we want to increase the level of social housing, but I think if you go out and look across Wales there are certainly a number of success stories that we need to shout about as well.


Craig, thanks very much. We'll come back to a lot of those matters that you've mentioned, and Sam's mentioned, in due course. James.

Just a question for Craig. On getting new planners into the system, it is a problem—it was a problem when I was in local government, actually, in terms of new planning officers coming through. How do you think we can make the profession more attractive for people to actually go into it? It's easy saying that we need to get more planning officers, but, actually, the delivery of that is more challenging. I'd just be interested in some of your thoughts on how we can actually encourage people to take up chartered town planning as a career route at university, or even at A-level, because you need to do geography A-level normally to be a chartered planner. 


I think we have to go back to basics and make people understand what planning is. Effectively, you are delivering the environment that we all live in, and it affects everything. It affects the place you live, it affects your job, it affects the way you travel, the way you move, the way you enjoy your recreation. I don't think people understand the level of importance that planning has for future generations in terms of setting out exactly how exciting it can be to create a place and really have that autonomy to deliver for people. It affects everything, and I think that gets lost sometimes with some of the more exciting jobs in terms of information technology and some of the things that younger people are attracted to. But I think we need to reinvigorate what planning can do for people in terms of delivering better lives for people. That's always been my mantra in terms of what my job is: to deliver better environments, to give people a job, to create houses, create options for people. So, I think for me it would be about trying to make the prospect more exciting.

I also think over the last few years with social media and with other aspects, being a planning officer sometimes is hard in terms of mental health, in terms of being quite strong in that position. So, I think we do need to have a think about how we can help planning officers with the amount of workload and with the pressures that you get in terms of how passionate people can be about development in their areas. But I think for me, and for getting younger people in, we also need to think about apprenticeships, not just about people who are qualified—so, how do we get people to learn on the job rather than that academic route. There needs to be other routes to get into this profession. So, for me, it's making it more exciting, looking at other routes, not just the academic route, and working on how we retain people already in the profession as well. We don't need any more people leaving because of mental health and because of the stresses and strains of the job.

Just to quickly pick up on Craig's point there, it's not just planners, as well—surveyors working in the public sector, building control officers, you name it, a lot of technical staff. Effectively, if you're really good at your job, the private sector is a lot more appealing financially to you. Craig's right, there is a lot of satisfaction to be had in terms of good placemaking. If you're a good planner, you can probably physically walk around what you are making and you get a good degree of job satisfaction with that. But there is that recruitment and retention challenge. How can you compete as a local planning authority with a private sector planning organisation if they're trying to recruit you? The salary differences, for a start, would be huge.

But just to look at that future talent part of the conversation here, the next generation of built environment professionals coming in, Wales has some quite unique opportunities coming forward. We've got—and RICS is a big advocate of this—things like the built environment GCSE. That's still in a very early stage. It's only a couple of years old and still not many schools or colleges have taken up that offer. But it's an opportunity to shape the curriculum to show the next generation what the built environment is—not just social housing, but the wider environment around us. But also in Wales we're just about to launch a series of built environment degree apprenticeships as well, which Wales will be the last part of the UK to offer. Luckily, we are doing so, because the problem is—and I've had this conversation with many surveying firms who would like to take on a degree apprentice—bluntly, they have to go across the border to England to do the course, and they are easily soaked up then by the English built environment market. So, it's about getting that home-grown talent, and hopefully we're going to see some progress over the coming years with that.

Thank you very much. How effective do you think are the current methods of measuring housing need nationally and locally? And obviously, if you think there's room for improvement, we'd be very interested in what you think those improvements should be, and how they might be achieved. Who would like to begin? Sam.

I'm happy to go. I appreciate colleagues over the last couple of weeks have talked about the varying high-level targets—the current 20,000, the need for the next 20,000, the right to adequate housing as well. I appreciate we've got the updated local housing market assessment as well, and I'm very glad that's come out since the height of the pandemic. I think that's a very important distinction here to take into consideration. What I would like to say is that, rather than looking at the quantitative measure, we should look at the qualitative measure of what we're looking at here.

Something Wales hasn't really got but England has, for example, is the English housing survey, which actually, when you look into the detail of that, looks at things like the condition of existing social housing stock, which is important to understand whether people need to move on from that. It looks at tenant satisfaction, how happy is a social housing tenant in their current property, because that would impact future demand. It looks at overcrowding. Social housing in Wales is in a better position than other parts of the UK—only 5 per cent or so is defined as overcrowded—but, again, that Welsh housing survey model could replicate it.

It also looks at affordability, but importantly as well, it looks at the demographic of people using social housing. That's something that we haven't really got a lot of detail on in Wales, not just in terms of single occupancy, family occupancy, but the type of people living in it. Have they got any special accommodation needs, disability requirements? What are their ages as well? Are we looking at potentially an older generation of people in social housing, which today is fine for them, but in a couple of years' time will not be suitable for them? It's having that sort of adaptability model, and that's where I think we've got a big data gap in Wales, is that qualitative data rather than quantitative, and that will certainly help understand what the future stock needs will be.   


So, previously we've had housing enablers or rural housing enablers who are supposed to assess what the need is locally, but I think in the previous session they said there were only four in 22 authorities. So, do you think having this Welsh housing survey would help with that or replace that need for the housing enablers?

So, the English housing survey model significantly helps the UK Government understand, I guess, the future pressures coming on the sector. It's all well and good knowing what the emergency waiting list is for accommodation today, but the model they use in England could help you understand the types of homes you need. The problem you would have is that transition, where you put somebody in and within a couple of months' time, the property is not suitable for them at all, so it moves on. The challenge is—. You've described there's only four people, for example, who are looking at that. It is a big piece of work to undertake, and it's that sampling model; it's understanding how it can be worked out effectively.

Okay, Carolyn. Craig, did you want to speak on this matter?

Yes, thank you very much. So, the local housing market assessment is great in terms of looking at existing housing need, rising need, the planned supply that's coming through the system, and it does have some great advantages in terms of being evidence based and there's consistent methodology across Wales then, so that you can compare apples with apples, if you like, across the local planning authorities. I think one of the big disadvantages about it, and it's this thing that we always discuss, is that we don't know what we don't know.

So, we only know the people who are registered on waiting lists. There might be people out there who are in housing need who are not identified to us as Welsh Government, as local councils—the people who can't afford a property who don't see themselves in housing need, but effectively they are, because they're still living at home or they're not able to get onto the property ladder or into private rented accommodation. There are loads of opportunities out there, such as shared equity, shared ownership, where you can own an element of the property. That's how I got onto the housing market—I owned 50 per cent of the property, the council owned the other 50 per cent. There are those products out there and I think we need to sell them more to people, to help people, to support people into the housing market and to get onto the housing ladder. So, I think it's what we don't know that is the big unanswered question—the people who don't see themselves in housing need. How do we contact them? How do we quantify that and how do we get a figure for that? 

I think sometimes, as councils, we're very much dealing with the social hosing sector as the most vulnerable people in society, which is correct—that is certainly an element—but there's also another element, a hidden element, I think, which is about people who are just starting out on their careers, junior positions, nurses, junior teachers, police. We should giving them a help up as well in terms of providing a home. It's the first right, I would imagine, in terms of having a roof over your head. So, that's the sort of thing we should be supporting as we progress. So, it's the unknown as well. So, it's a great tool, the local housing market assessment, with great advantages, but what don't we know, that's the big problem in terms of what's out there that we don't know about. 

Diolch yn fawr. Okay, we'll move on to Siân Gwenllian. Siân. 

Diolch yn fawr, Gadeirydd, a dwi'n falch o ymuno efo'r pwyllgor yma. Ar ôl cyfnod o weithio ar y cytundeb cydweithio, mae'n braf bod yn ôl yn craffu yn y pwyllgor yma, a dwi'n meddwl bod y maes yma yn un pwysig ofnadwy i ni fod yn edrych arno fo. Os ydyn ni'n llwyddo i adeiladu mwy o dai cymdeithasol, mae yna fuddion iechyd, buddion cymdeithasol, a buddion economaidd yn deillio o hynny hefyd. Felly, dwi'n falch iawn o ymuno yn yr ymchwiliad yma, er ei fod o ryw hanner ffordd drwodd, onid ydy, ond gobeithio y medraf i gyfrannu tuag ato fo.

Gan edrych ar y maes cyflawni, sut ydych chi'n meddwl y dylem ni gydbwyso'r angen i adeiladu cartrefi un ystafell efo'r angen i sicrhau cymunedau cymysg?

Thank you, Chair, and I'm very pleased to join this committee. After a period of working on the co-operation agreement, it's great to be back doing scrutiny work as part of this committee, and I think that this area is a very important one for us to be looking at. If we are successful in building more social housing, then there are health benefits, social benefits, and economic benefits that come from that too. So, I'm very pleased to be part of this inquiry, although it's about half way through, isn't it, but hopefully I can contribute to it.

So, looking at delivery, how do you think we should balance the need to build one-bed homes with the need to ensure mixed communities?


Yes, happy to go. I think it's really important to look at this sort of mixed-community model, for starters. You do not want to be in a situation where—. A lot of people in social housing could be, potentially, vulnerable people. You do not want to create an environment where a lot of these people are almost captured into one small part of the community. It's that sort of mixed model. We've got some good examples of where that's worked. The Mill, in Canton, in Cardiff, for example, is a great example, where you've got a good blend of owner-occupier, privately rented sector, and social housing provision there. And actually, if you go around that site, that is a beautiful new development. It's got a good sense of placemaking within that.

The important point, though, is understanding what sorts of properties are needed. How can you understand how many one-bed properties are needed, how many two, three-bed homes? That goes back to the point I was making about that English housing survey model as well. It's all well and good knowing that you've got a waiting list of several tens of thousands of single occupiers to take on that property, but what sort of accommodation are they looking for here? Bear in mind as well that, for a lot of people, especially since the pandemic, a one-bed house is not suitable for them. A lot of people, for example, are now looking for two-bed homes, where they can have flexible working arrangements, and things like that, which shouldn't exclude the social housing part of the market as well. I would emphasise that mixed-community approach—it's certainly the model to go after.

So, what you're saying maybe is that we don't really know whether the one-bedroomed stat, if you like—. We're being told all the time, aren't we, that we need more one-bedroomed properties, but you're saying maybe that that doesn't quite stack up anyway?

The problem is, it's difficult to capture a one-size-fits-all approach, depending on who the people on waiting lists are, for example. If we were having this conversation in 2018, 2019, we could certainly say, 'Yes, a one-bed house for one person or couple is fine.' We might be in a bit of a difficult position now to try and justify that. Obviously, the priority is getting the accommodation built, but it's that toss-up between, do we get as many one-bed houses up as possible, where the quality of life, for example, might not be perfect, or do you focus on a smaller number but a much greater, higher level of satisfaction, of retention, of care for individuals?

The need for one-bedroomed houses has increased quite significantly over the last few years. That has been driven by changes to the homelessness legislation, following the pandemic. So, some of that has increased. The local housing market assessment gives us really good guidance on what the need is in specific areas. So, we definitely need to plan our new developments to have a mix of different property types, in terms of our placemaking principles. We wouldn't want to have the same house type across them. So, I think we need to have a balanced demography; we want balanced communities, different ages, and different house types, ultimately. So, we do want to provide new developments that address that need, certainly, that have a high level of one-bedroomed developments, but we also need to cater for the wide range of people, ultimately, across that development proposal, and there's only a certain amount of homes on that particular site.

So, I think the need for one-bedroomed houses has certainly gone up because of the changes in legislation, but I think the evidence shows that people don't live in those properties for long. We need to provide those lifetime homes as well. Monmouthshire Housing Association have done some quite significant work in this area, in terms of homes that can be adapted to people's needs over time, as their life changes, throughout their lifestyle, and through their life-cycle. I think that's really, really important, having homes that are able to adapt, particularly public housing stock, which should be adaptable and flexible to move with people as they move through life. And, potentially, as they get older, they might have different needs and housing requirements, and there will need to be adaptations done to the home. So, I think we need to make sure that particularly our public housing stock is adaptable and flexible, to move over the life-cycle of people.


Mae yna rai tystion wedi galw am gorfforaeth ddatblygu hyd braich i arwain ar reoli tir strategol a chyflwyno safleoedd ar raddfa fawr. Ydych chi'n cytuno efo'r farn yna? Oes yna le i fodel o'r math yna?

Some witnesses have called for an arm's-length development corporation to lead on strategic land management and bring forward large-scale sites. Do you agree with that opinion? Is there scope for that kind of model?

'Yes' is the simple answer there. Look at England and Homes England, the role they have in delivering affordable housing and unlocking land—that's a good model to use as a benchmark. I think also importantly as well, factor in something like the Office for Place, which was set up by UK Government quite recently, which focuses on actually creating beautiful environments. I think that's an important factor to consider as well, that when we look at not just social housing, but overall, new-build housing estates, pretty much you can always guarantee every single large application will have a large number of objectors to it. Something like the Office for Place, designed to actually make sure new-build estates are beautiful, they fit in with local culture, local heritage, they're actually quite inviting places to want to live, walk through and enjoy. So, I think I would have that blend between a body that can set the standards, good design codes, to actually make sure buildings looks good, which helps with that social cohesion, getting community buy-in to this work, and then a body like Homes England, which can oversee that affordable land unlocking.

The other point I would stress, however—and I've had conversations with colleagues in the public sector across Wales—is there's still a big unknown of actually how much land the public sector owns in Wales. Some bodies you speak to might not even have an understanding of a third of the land they actually own. So, if a body like this was to be created, there is a big challenge, first, of actually understanding who owns what, and from there we can then start working backwards, to actually understand, 'Right, we've got this plot of land, how many properties can be build on it?', and then going forward from there.

But isn't the land division within Welsh Government supposed to be doing that kind of work?

They are, and we are working with them closely. But the problem is you're working off, potentially, plots of land that are hundreds of years old, in some form of ownership, so trying to track down some historic ownership is a big challenge. And I mean, some plots of land could be fields; others, we're talking literally small strips of land that you couldn't put anything on, you probably couldn't even walk on them. But it's trying to firstly map out actually who owns what, and I think that's a big challenge to overcome.

I think I'd question whether we need another vehicle, when we've already got a number of registered social housing landowners across Wales, and we've got councils—should the councils be building again? Should we be looking at using compulsory purchase orders more to buy land and bring strategic sites forwards? Should we be investing in the vehicles that are already there and already exist, but upscaling them, particularly registered social landlords? Could they be more competitive, could they be more strategic in the way they think, and could they have more investment to deliver? And they should be measured on that, ultimately. 'Do we need another body, or are there existing bodies out there?', is the question that rises in my head when we look at this. I think there are probably other things we could do better in the existing model rather than creating another level.

In terms of unlocking land, I mean, that would be one benefit, presumably, of having an arm's-length body, but what would be other benefits in terms of the supply chains, procurement, looking at all of that in a strategic way, which perhaps isn't happening now? But I guess there's a difference of opinion here: you're saying 'yes', we need one, and Craig is saying he's not quite sure.

I don't know whether another body would unlock the land. I think the same challenges would be there in terms of that historical land ownership and getting people to land and then going through the planning process, which will be quite significant. I don't know how another level of bureaucracy and another route would do that, when there are existing registered social landlords and councils out there that have the power to deliver that. It's just whether we're using those powers enough, I think, is the question for me.

I think I would say that if a body was to be created, it also needs, to come with it, planning confidence. I've done a lot of research in the last couple of weeks, speaking to people in organisations like pension investors, for example, where, actually, regardless of the type of building stock they're looking at, UK residential real estate is right at the top of their risk portfolio to invest in, because they have absolutely no guarantee; you can throw thousands of pounds in in terms of prepping an application just for it to be rejected straight away. There is not that confidence in that sort of investment market, and housing associations are in the exact same position as well, who are struggling financially given the constraints we talked about earlier on about managing existing stock. So, actually, they need to be realistic in terms of thinking, 'If we want to build several hundred new properties, is it worth the investment if we have no confidence that planning is going to get over the line?' And that's where I think if we can have a body, say, unlocking land, where there is a strong degree of confidence that that planning process will get approved relatively easily, and we're not talking months or years of delays—. 


I'm not keen on arm's-length bodies. Do you think there's sometimes a lack of ambition sometimes within, say, local authorities and some housing associations as well to actually get on and build? Because local authorities are naturally risk-averse people; Carolyn and I have both sat around cabinet tables where you get senior council officers who are very risk averse. They don't like taking a risk on anything that looks a 50:50 development; it's almost got to be 100 per cent or they won't even touch it. And that's sometimes a little bit the same with housing associations to a degree. Do you think there is sometimes a bit of a lack of ambition within the public sector to get on and actually build the housing we need, and they're a bit frightened to take a punt and a bit of a risk sometimes?

Without wanting to represent all chief execs of housing associations—

There is certainly that sort of ambitious need. It goes back to the start. It's about that target: actually, how many homes do you need and where do you need those homes. That's an important factor as well, actually: how many homes does Cardiff need long term, Swansea, et cetera, and how do you mandate targets, for example, or are we just using a voluntary target? I think housing associations naturally, they want to provide; that is their sole purpose, and I think the people working within housing associations have a strong, ethical reason to be wanting to work in them as well. The challenge is, especially in recent years, the financial constraints, and they've got to be realistic, that, actually, they've got to meet things like the Welsh housing quality standard to actually maintain current legislation and actually make sure they're adhering to the rules, and that, quite rightly, sets a high bar, a high degree of standards, but they need to be realistic and set that and to maintain it, and that, unfortunately, comes at a cost, mostly to new developments. 

All right, James? Okay. We're up against it in terms of time, I'm afraid, so we'll have to be shorter with our questions and answers, but Siân had a further question.

Ie. Rydych chi newydd grybwyll safonau tai. Ydych chi'n meddwl bod angen mwy o hyblygrwydd o ran y safonau i gefnogi darparu mwy o gartrefi cymdeithasol?

Yes. You've just mentioned housing standards. Do you think that there should be more flexibility in terms of housing standards to support the delivery of more social homes?

Who wants to go first?

Happy to go. So, unsurprisingly, the Royal Institution of Chartered Surveyors, everything we base ourselves on is professionalism and standard setting, so you won't be surprised to hear that standards are the top priority for us. With that in mind, things like the Welsh housing quality standard, the Welsh development quality requirements—WDQR—that does set a high standard, I think it's fair to say, and it's that toss-up, really, between delivering high-quality standards or a larger proportion of homes that probably don't meet a higher level of satisfaction to actually live in and quality of life and health and well-being, actually. Should there be a degree of flexibility? Yes, to an extent. When we look at things like conservation areas, listed properties, historic buildings and being realistic about the costs of refurbishing these and turning them into social housing provision, the statistics, it's a small percentage in Wales of social homes that fit that conservation, historic property, listed buildings criteria. What I would say, though, standards aside, is we've worked very closely with the department of levelling-up in England, who are looking at introducing minimum levels of conduct and competency for those managing social housing. So, rather than actually setting the standard for what the block should look like or the home should look like, setting the standard for actually the quality of the people managing the property—so, minimum qualifications for housing managers, those responsible for development, the maintenance of it, which can actually help uphold the standard, and there's no reason why that couldn't be applied to everybody involved within that space.


Yes, I think there has recently been some flexibility provided by Welsh Government in terms of acquisitions and some of that quality element, which is really positive and I welcome. I think the ask would be, ultimately, about putting this on a par with the private housing market. So, I think the building regs need to change, generally, in terms of meeting net-zero standards in any case. So, I think, across the board, we should be putting the two on a par and increasing our energy efficiency, in terms of the cost-of-living crisis and the climate change agenda. So, I feel that, at the moment, we need to be driving further anyway, in the private market as well, in terms of quality. But I suppose that is a different kind of conversation. But, certainly, I would argue that we need to put affordable housing and social housing on a par with private, open-market housing to enable provision to keep going and stock to keep coming through, but also raise the bar again anyway in terms of net zero.

Okay, Craig, thank you very much. And thank you, Siân. Carolyn.

We've talked about social housing being held up by delays in the planning and consenting process. Do you think that we should prioritise social housing? That's been suggested to us by some RSLs. So, if the planners are looking at a lot of planning applications, should we prioritise social housing? What are your views on that?

And I just want to ask as well another question to tie it in: is there consistency across local authorities as well? So, it was mentioned to me that some go through delegated authority, but some go to planning committee. It might take a bit longer because of that process.

Do you want me to go first on this one?

So, every council's got their own constitution. So, their scheme of delegation will be slightly different in each council across Wales. So, it depends what that council, those members, have agreed. Some might be delegated, some might be full planning committee, and each scheme is completely different, and each council is going to be different in that, so they have different structures and a different process.

In terms of prioritising social housing, I think that's difficult in terms of parity, in terms of fairness, in terms of everyone paying a planning fee and having their process, so I think that is difficult. I think what we need to concentrate a bit more on, potentially, is upping the provision of affordable housing on strategic sites. So, as part of that place and local development plan, when we're looking at sites, some authorities are getting minimal, in terms of 10 per cent of the site being affordable, 20 per cent being affordable. Should we be pushing for 50 per cent of our sites to be affordable? Should we be looking to really raise the bar, ultimately, in terms of Wales? If the development of a private house builder can't deliver 50 per cent because of viability, is that fair then that the public sector does step in and provide that funding and that investment to deliver that higher level of affordable housing? I think land is so precious in Wales, given climate change and green fields, we should be using that land really, really efficiently and effectively, so I think having public funding subsidies that prop up and that deliver social housing on the sites would be my preference in terms of delivering more.

I think, looking at the functions and functionalities of individual councils, I think that's down to those individual councils and those members to have that autonomy. But I think having the right strategic sites with a high level of provision of affordable housing is the way that we're going to get more through the system.

I would caution against a priority approach for social housing, partly because, going back to your point about being ambitious, if you were a big private house developer, which do have a role to play in social housing delivery, actually, they might think, 'Why would I bother putting an application forward in Wales if it's going to be at the bottom of the list?' Whereas, in other local authorities in England, it would be top of the list. So, bear that one in mind.

Secondly as well, don't forget, some applications, big developments, for example—section 106, you've got that mixed use and you've got developers who are building owner-occupier, build-to-rent properties, but, actually, there will be a social housing or affordable housing element to it at the very minimum. So, it would be very difficult to police that.

And, finally, I would caution on that priority approach, because that's almost opening the door to permitted development rights, which could, ultimately, almost remove a layer of—people call it 'red tape', but—actually ensuring that the properties are in a good location, local infrastructure's there, they're being built to high standards, safety specifications, sustainability et cetera. There is a concern that, if you prioritise something like that, is it just simply permitted development rights through the back door?


Okay. So, my second question is: to what extent are statutory consultees causing delays? So, we talked earlier about scarcity of planning officers and ecologists et cetera. I know there's some scarcity, but is there another issue there, do you think—

No, go on, Sam, it's okay. 

I was going to say Craig will know the sorts of statutory consultees a lot better than I would. What I would say, from an RICS perspective, and the conversations we've had with our surveyors, who every day work within that planning space, advising clients on putting forward applications—. It goes back to the conversation I think we had earlier on about, actually, the resource and the people within it. We talk about the shortage of planners within local authorities, but there's a shortage of pretty much everybody responsible for statutory consultees, and, actually, there is merit in considering whether or not a one-size-fits-all approach that everybody, every statutory consultee, must be required for a development in central Cardiff, compared to a development in rural Wales, for example. It's having that bit of a flexibility model. 

Do you think there's enough of a balanced view? So, for example, NRW might say, 'This is high flood risk, no way', but then somebody else might say, 'Well, actually, with mitigation, that's okay'? Do you think there's enough of a balanced view going forward on some things, or a pragmatic view?

Yes, I would suggest there is. I would suggest—. In terms of statutory consultees, such as NRW, Welsh Water, external to local planning authorities, I would suggest, over the years, they've got targets, they've got hit, and that has improved, I would suggest, over the years. I think, going back to Sam's point, in terms of internal resources in councils and highway authorities and drainage authorities, in those bodies, which are so pivotal now in terms of planning decisions, they are sometimes lacking. And it's back to that resource question, in terms of how do we get people into the system. In terms of making a balanced view, I think planning committees are doing that across the country. I think they are. Planning officers, I know, that I work with—my colleagues across Wales—are, certainly, taking those balanced views, making those decisions, and then it's down to the planning committees to make that ultimate decision, ultimately, in terms of how we go forward. I think we do have to remember that planning isn't 'computer says "no"', it is grey. It needs sometimes to have that balanced decision. 

So, is there anything—? What more can be done, then, do you think, to speed up planning? Is there anything that we've missed? Or for viability or—? 

I think, for viability, it would be good on a national level if we set targets in terms of what we expect the developer to have in terms of profit, what's an acceptable range in terms of looking at that, and it would be helpful. A lot of councils use a district valuer to look at viability of schemes, but is there something that could be agreed more at a national level, which then could open the door in terms of funding and public funding, and when that can be used and when it shouldn't be used? So, I do question whether we need some help and support there. I think viability is always a concern. It's a black art. It is something that sometimes can be a bit difficult to manoeuvre through. But I think, yes, a bit more support in that area would be welcomed, I would imagine.  

We talked about viability earlier of sites for social housing, especially from the private development part of it. And I've sat in plenty of planning committees where, actually, you get developers coming in pleading poverty, saying that, 'If we put x amount percentage of social houses on this development, my development is not going to be viable', or it tends to get rejected or something by planning committee, comes back and then there's less social housing in there. Then the developer will plead poverty again, and you've gone from having, say, 50 per cent social housing to having 3 per cent, 4 per cent, 5 per cent in there. But what we've found, in some evidence we took, is, actually, the expertise is not there now, currently, within local authorities to fight back against some of these developers. So, what do you think—? Is there a role there for Welsh Government, perhaps, to provide some level of legal support or some type of support there to actually help LPAs in these negotiations with developers, and to give local councillors, sometimes, that confidence that, 'No, you can push back against these developers, because it can be done', because private housing is, actually, more profitable than putting up social housing. So, there is that sort of element to it as well. So, I would just love to get your views on that, if that's possible, please. Thank you. 

Do you want me to answer this question? 

So, I certainly think that that would be beneficial in terms of viability. I think sometimes local planning authorities are nervous about appeal processes as well, so when it goes to a planning inspector and the evidence is looked at, there's a chance that there might be costs against the local planning authority for not—. Say, for instance, a policy was 30 per cent affordable housing and the developer was only offering 15 per cent but the planning authority wanted to stick to 30 per cent, there's the nervousness around, 'Will that be backed up at a planning inspector stage?' It should be, if that is the policy level, but a lot of these policies are underwritten by their viability. I think if we stick firm to that 30 per cent, and we outline that that land has only been allocated to deliver that 30 per cent affordable housing, then I think eventually that will be delivered, ultimately. And this is where I think some support in that viability sector, from maybe the Welsh Government or from a local body, maybe just having a viability calculator across Wales or something like that that we can all rely on and is that utilised model, would be useful, and being open and transparent about it. We accept that the private market need to make profit. We're not saying that. There needs to be an agreed level of profit and an agreed level of social housing provision as well. I think I would agree that it probably does need that level of support. It sometimes can be acted as a bit of a black art. In Monmouthshire County Council, where I've worked, we did have an allocated site policy, and it was surprising how easy it was, suddenly, to deliver the amount of affordable housing that was required outside of the planned period. So, that was quite an interesting proposition when the land is starved.


Yes, there's nothing I would disagree with with what Craig was saying. There is a caveat that, especially in the last couple of years, developers, we know, have sort of gone down that appeal approach because of varying pressures—things like rapidly rising inflation, material costs, labour—which have, in the space between putting through a planning application and actually starting to deliver homes, had a huge impact on profit margins. The challenge we've got is that section 106 is the very last thing they will often deliver, pretty much at a time then when they can then turn around to the local authority and say, 'Actually, we have delivered well below the profit margin we thought we were going to deliver.' We've got that challenge there, and it does put local planning authorities in a very difficult position, and councillors as well, that you're going to have to push back on some of the big house players, who are probably prepared for a drawn-out appeals process. So, it's actually trying to understand how we can get that balance between not waiting until all the private home ownership aspect is done and then going for that section 106, which unfortunately is the very last thing they consider.

Lovely. Yes, I think that answers my question, actually—my next question as well. One thing the Cabinet Secretary for planning has talked about is actually moving the planning process to more of a regional basis under the corporate joint committee structure. I'd just be interested to get your views on that, because that is basically taking away a bit of localism then, isn't it? Powys, which I represent—that would be taken away, with Powys and Ceredigion making decisions on planning matters. That comes with its own controversial element, but I can probably see where the Cabinet Secretary is trying to get to with speeding things up and making it more strategic. But where do you think that fits, then, perhaps, with reforms to LDP processes? Do you think they should be done, then, perhaps, at a more regional basis under the corporate joint committee structure? Do you think that could perhaps help the system? I have my own personal views on it, which I could answer, but I'd love to hear yours.

Your latter point about what impact would that have on LDPs—it is removing that element of localism. Planners who will know that local area—you're not coming in having never visited that local community or even visited that local authority before. It is a difficult element there to address, and I think that's where it comes down to that sort of community engagement aspect of it and whether or not we can strengthen that. I mean, there are ongoing conversations across the UK about things like street votes and greater engagement with residents, which quite frankly just could be a nightmare for a lot of planning applications. But, actually, moving that joint model, shared service-type approach, does answer a growing challenge we've got about resource allocation. I mean, we talked about that sort of joint planning model. We're having similar conversations about joint surveying models with public bodies with local authorities as well, who are stretched, and building control officers as well—critical to building safety. Not all local authorities are in a position to employ the adequate numbers for them, so whether or not they have to share the specialisms, and I would go so far as to say that for planners—Craig might have a different opinion—who are specialists in social housing delivery, affordable housing delivery, it's better to probably share their expertise across two or three planning authorities than have them focus just on one planning authority, but, really, some of them only deliver a small percentage of what the overall work is.


I think we could have a whole session on regional planning, but I think in terms of my view on planning, I believe in regional planning. I believe in the principle of it, I think it's the right thing to via the corporate joint committees in terms of aligning it with the regional transport plan as well. If we're enabling sustainable development, that's the way to go in regions—I totally agree with that.

The question is how far it goes in terms of localism and the strategic development plan manual at the moment—I think the way it's worded and in terms of what the regional plan will do, it probably goes too far. I think that's probably something that needs to be looked at. I know it's going to go out to consultation later in the year and I think that's when local authorities and councils will be able to get into that detail. But we need to look at the functionality of that regional planning—what it can achieve. It needs to be strategic in its nature rather than going too far into local issues. I think local councils still have a role here to deliver and address the local housing need that they have and they should have the autonomy to do that as well. So, I think, to pick up on that point that you were making there, James, that's really, really important. And we need to think about what role that regional plan has. I believe in it, I believe that the planning system and the regional plan certainly need to be part of that, but I think we really need to think hard and long about what that detail should be and it should be strategic.

Thank you, Chair. Good morning. My area of questioning is about construction and communities. Now, with regard to the construction, we hear so much about modern methods of construction, use of digital tools, construction-focused courses, targeted training and diversity initiative and strategies. So, my question is: how should we develop construction sector capacity and skills to build social and affordable homes?

Modern methods of construction, MMC, is a really important point and I know it's something that the Minister for housing and planning previously in post, the Minister for Climate Change, really put an emphasis on—modern methods of construction. There was a lot of investment going on prior to the pandemic and I think that took a back seat when COVID started.

Quite recently, the House of Lords did an inquiry, as they worded it, 'Modern methods of construction—what’s gone wrong?' I'll leave you to be the judge of whether that's a slightly biased title, but a fundamental point that came out of that is that MMC is great, good quality, sustainable and can be economical, but it needs demand. MMC, for a lot of development, is not profitable if it's only 10 or 12 properties you're using it for—you need potentially hundreds of properties to actually make it profitable, especially if you're going to be investing a lot of resource into retrofitting out a local warehouse or factory, upskilling local resource. That was one of the priorities of MMC—it was about those sorts of local skills and local employment. It needs that demand, and one of the big problems we had in the inquiry that we're looking at with the House of Lords was that developers would love to use MMC. Actually, for a lot of developers, if the quantity was there, MMC was very profitable for them. But you can always guarantee that a lot of the planning applications put forward would not get over the line, not because of MMC, but for the variety of planning reasons you're all familiar with.

What I would say is that a potential opportunity to look at in Wales is when we look at the procurement side of things—whether or not we can explore opportunities for embedding extra weighting for developers who come forward and say, 'We're going to do x amount of the development using MMC or all the properties there.' I'ts just trying to have that bit of incentive. I would caution against setting a mandatory target for developments of MMC on certain developments, just because it will lead to a lot of viability and economic challenges, because it's likely that they will be small in scale. But I think that if you look at the procurement route where you can encourage—not mandate but encourage—innovative construction solutions, that would certainly get the market moving.


Okay. Craig, would you agree with that answer or did you want to add anything?

I don't think I'd add anything. I'm probably not best placed in terms of this conversation. Maybe in regard to the net-zero conversation, I think, for me, it's just about making the properties as energy efficient as possible. I think you should be doing that by the building regs, ultimately, across Wales. We should be upping that standard for all properties, not just for social housing.

Great, Chair. Thank you very much. Yes, it is about communities. Building trust and open communication are lacking when we talk about social and affordable homes. So, my question is: how can communities be effectively engaged in social housing developments in their area? What good practice are you aware of in building local support for new developments?

I appreciate this is quite a big area, and we've probably got about two minutes to answer, so I'm afraid that—. If you could point us to the headlines.

RICS would advocate some of the points we raised earlier about things like Office for Place, making sure that these developments are beautiful locations, they're not just new-build estates, one size fits all, it all looks the same, and you've got 500 homes where you'd probably just get lost walking around the estate, because you have no idea which home looks like what. You will always have challenges with Nimbyism in development, not social housing, not affordable housing, but all housing, if I'm honest, or any development, ultimately. You can get communities on board, I mentioned the Mill in Canton earlier, which is a fantastic example of a good, mixed-use development, an excellent environment to walk around. You've got different tenures mixed together, built basically surrounded by long-standing communities as well. So, I would stress that it's having that mixed-use approach, having that emphasis on—I hate the phrase—beautification of developments as well, so they fit in with the local environment and they are attractive places to live, and, if you're a pre-existing resident, actually to look at as well.

I think registered social landlords, RSLs, have got a role here in terms of engagement with communities and ensuring, from the very outset, in terms of the development proposals, that they're having those conversations with communities. The council, via the planning application and via the placemaking plan, engages significantly with communities. I agree with Sam in terms of you're always going to get a level of Nimbyism, but it's about educating people, being open and transparent with people, and I think RSLs have a role there to play as well, ultimately, in terms of those conversations. I think that's all to be happening at council level. RSLs probably need to do a bit more of that pre application, pre-planning application, so that things don't come out of the blue.

Okay. Thank you very much, and thank you, both, for giving evidence to committee today. It's been very useful. You will be sent a transcript to check for factual accuracy, but diolch yn fawr. Thank you, both. Okay, committee will break very briefly and resume at 10.20 a.m.

Gohiriwyd y cyfarfod rhwng 10:13 a 10:20.

The meeting adjourned between 10:13 and 10:20.

3. Cyflenwad tai cymdeithasol: Sesiwn dystiolaeth 7
3. Social housing supply: Evidence session 7

Welcome back, everyone. We've reached item 3 on our agenda today, which is our seventh evidence session on social housing supply. I'm very pleased to welcome, joining us here in person, Avril Roberts, senior property and business policy adviser with the Country Land and Business Association—croeso, Avril. Joining us virtually is Ben Murphy, estates director with the Duchy of Cornwall—croeso, Ben.

Okay. Let me begin, then, with a couple of overview questions. First of all, Avril, for you specifically, could you summarise the major challenges in increasing social and affordable housing supply in rural areas?

Absolutely. Firstly, thank you for having us speak to you today. It's such an important issue for the CLA, as it is for everyone across Wales. There are, I think, four general points to make with the difficulties of increasing supply. The first, particularly in rural areas, is identifying that need. What we see quite a lot is that the methodologies that are used to assess need don't accurately capture the true need in rural areas. Quite often, because of house prices, people have already been forced to move out of those communities and the assessments don't capture the people who've already been forced to leave, so that's a primary issue. Secondly, they don't accurately capture need that might be households that don't necessarily qualify at the lowest end of social housing, but that doesn't mean that they can still afford market housing and therefore they do need access to some affordable housing, and those households aren't identified on those needs assessments, either. 

Secondly, because that need has not been correctly identified, then getting planning permission can be quite hard, and, again, that's a particular challenge in rural areas, because these villages, these parishes are often deemed to be unsustainable; they've perhaps lost their bus service over time, perhaps their village school is at threat, perhaps even closed already, the village shop might be not doing very well. And so, under how planning applications are assessed, those villages are deemed unsustainable. What we'd like to see is a flip of that, so, actually, if housing were enabled, would those villages become more sustainable? So, would the village school be able to be kept open because there are new families living in that community and who would, perhaps, use the bus service? So, we'd just like to see that flipped, but, at the moment, that's a major challenge.

Thirdly, I think the elephant in the room is planning. I think we might, perhaps, come on to planning in more detail later. But, we do know that this is a significant barrier, not least because developers, landowners, housing associations might be put off putting in applications because of the challenge of planning—very high upfront costs and, actually, if the outcome is so uncertain, as it is, actually taking that risk on those high costs so early on in a development is massively off-putting.

And finally, as a general point, the cost of development is still very high. Talking on behalf of landowners, I think we would think there's a misconception that land is always the barrier. Actually, if you're doing an affordable housing development, you value it on a residual land basis, so you take the cost of the development and you offset it against the income over a set period of years, and your land value is what's left out of that. So, yes, while there might be some disagreements about expected land values, actually, the price that can be paid is quite often not the barrier; it's about £2,300 per square metre to build in Wales, which is about £230,000 for a typical three-bedroomed house on a low spec, which you would expect with affordable housing. And that is, frankly, too high and that actually is just a massive barrier. So, I think they're the four general points that we would make.

Okay, Avril. Thank you very much indeed. And, Ben, could I ask you for an overview, really, of how you planned and delivered the development of Nansledan, if I've pronounced that correctly?


Thank you, John. You did, indeed. Nansledan is Cornish for broad valley. It's an urban extension to Newquay, where I'm based at the moment. It's the Duchy's second largest—well, it's the second strategic project, and it will be its largest in due course, with Poundbury being the first, which perhaps is more well known.

In terms of an overview, as a major landowner, we've found ourselves over the years becoming more involved in development because we were upset at the quality of what was being delivered on land, where we would step out of the way for a local planning process, when elected members would make a decision on the growth of the town. In this case, Newquay and also Truro were identified as major growth areas by Cornwall Council. But, Poundbury and now Nansledan are examples where we've taken much more of an active interest as a landowner. In the past, we would have just stepped out of the way because we're a rural landed estate, and relied on good-quality, local, private house builders to deliver local needs. We found, post war, that the quality, especially of social housing, wasn't to the standard it should be and wasn't integrated with affordable, wasn't creating the opportunities for jobs and a balanced economy. As a landowner, you have a vested interest in the success of these areas.

So, what happened in Nansledan was, in 2005, there was an inquiry by design. That was established by Cornwall Council. Originally, they were looking at 400 homes. It then transpired Newquay needed quite a lot of infrastructure—new doctor surgeries, schools and suchlike—and it was actually the head of planning at Cornwall Council who said, 'Let's put a bigger red line around Newquay.' It became the Newquay growth area and 4,000 homes, and the master plan was guided by the local community. That gave us the broader shoulders to deliver more of those local needs.

So, from the Duchy's perspective, it is an interesting point raised about land. We use our land as leverage. And of course there are those who want to sell to the highest bidder, and then land becomes part of the viability issue. From our perspective, we invest our own money and we recycle land receipts into delivering a lot of the social infrastructure, which helped in this case bolster the town of Newquay, regenerate the town of Newquay. We're delivering 30 per cent affordable homes at the moment. No-one is delivering higher than that. The policy level is 35 per cent, and our aspiration is to achieve 40 per cent.

But, if I could just give you a blunt assessment of the financial metrics of this, the Duchy chose—. It's a private estate, so it could potentially have pursued some Government support, but our role is to provide an income for the heir to the throne, for the Prince of Wales and the Duke of Cornwall, independent of the state. So, we've never sought any public support. Also, because of who we are and the aspirations of our previous boss, and now Prince William, our current Duke, we have a real patient approach to capital. What I mean by that is, if you were another landowner, you'd probably need support with infrastructure and perhaps subsidy to deliver the levels of affordable homes, because it's those two things that have put a drag on the financial metrics. By that, I mean the Duchy has spent about £32 million to date, will break even probably around 2030, and there is another 15 years of the project to go. Bearing in mind we started in 2015, the consent was 2012, and that means we're 15 years in before we break even. I don't know anyone in a private capacity who would ordinarily do that.

In speaking with the likes of Homes England and the department for levelling up, we think they and Government agencies can and should do more of what we do. If we were to do this again, and we hope to, perhaps we should have looked for more support to deliver the infrastructure in the early years. I'm talking about the schools, the roads and all the good things that we have delivered that support this community, which is about 700 homes in. So, it's quite a way to go to deliver the 4,000 homes, and we hope 4,000 jobs to go with that, because it's a mixed-use, walkable community.

Thank you very much, Ben. That's very interesting. Okay, we'll move on to other committee members and, firstly, Siân Gwenllian.

Diolch yn fawr. Cwestiynau ynglŷn â chyflawni. Oes angen mwy o hyblygrwydd mewn safonau tai? Dwi'n sôn am safon ansawdd tai Cymru a gofynion ansawdd datblygu Cymru—mwy o hyblygrwydd er mwyn gallu cyflwyno mwy o dai cymdeithasol. Mae'n debyg mai cwestiwn i Avril ydy hwnna.

Thank you very much. I have some questions on delivery. Should there be more flexibility in housing standards? I'm particularly thinking about the Welsh housing quality standard and the Welsh development quality requirements. Do we need more flexibility to bring forward more social housing? I suppose that's a question for Avril.


Thank you. So, firstly, housing standards and particularly decarbonisation are incredibly important, but we do need to be realistic about what's possible in rural areas today. I'm not talking about in the future when we've put in, hopefully, the infrastructure to support these developments, but, today, the infrastructure is simply not there. If we want to reach a very high EPC standard for new-build housing in rural areas, we're talking about electrical heating, we're talking about car charging points, we're talking about putting a lot of extra strain on the electricity grid. And I think it was in our written evidence that 25 per cent of Wales is in a national park or a protected landscape, and so, if you want to put in overhead cabling to increase the electrical grid capacity, actually you're going to be restricted from doing that, so you might have to go underground, and then you might not get permission for that, and even if you did, it would be a lot more expensive. So, reaching those standards is a very long way away. 

Additionally, if you've got a rural area that has got a particular vernacular style, and actually those materials are very old, they might not be properly assessed using the current methodology that's used on energy performance certificates, and, actually, if you wanted to reach those high standards, you might have to change the materials you're using, or potentially spend a lot more money on very fancy, for want of a better word, materials that have been developed. And, actually, if you're delivering social or affordable housing, as we know, the ability to pay more for the materials that are going to reach those standards might not be there.

So, in answer to your question, do we want more flexibility? I would say 'yes' for now, or if there can be some form of subsidy to meet those standards. But even with subsidy, I simply don't think it's possible, with the grid infrastructure as it is. So, yes, flexibility, but with a commitment that those homes, at some point in the future, will be upgraded, and a commitment to better the infrastructure so that we can get there sooner rather than later.

Ben, roedd y datblygiad gennych chi yng Nghernyw yn cael ei gyfyngu oherwydd bod yna safonau uchel yn cael eu gosod. Oedd y safonau yna'n rhwystr? A gyda llaw, enw'r lle, Nansledan, roeddech chi'n dweud 'ledan'—wide. 'Llydan' ydy'r gair Cymraeg am wide a, ledan, maen nhw'n debyg iawn yn fanna. Mae'r cysylltiad rhwng yr iaith Gymraeg a'r iaith Gernyweg i'w glywed yn syth yn yr enw.

Ben, your development in Cornwall was limited because high standards were set. Were those standards a barrier to your development? And by the way, on the name Nansledan, you mentioned that the 'ledan' element means wide, and 'llydan' is the Welsh word for wide, so it's very similar in Cornish. There's a clear link between Welsh and Cornish, which can be heard immediately in that name.

Absolutely. Thank you. I wish I had some Welsh to respond to you with. I would say that all the street names here are in Cornish, and we are celebrating reviving the Cornish language as much as we can, but, obviously, the Welsh have led the way very much in that regard over the last generations. I think the strength of character and identity of what we're trying to deliver here in a Cornish vernacular is why it's been so well received and supported locally, and it's really helped bind the community together. So, thank you for your inspiration, I should say, from Cornwall.

On the quality, it sits uneasily with me, but I totally understand Avril's response. And I say that because we deliver tenure-blind homes, which is to say never underestimate the importance, I don't think, especially for young people, to help build their confidence and recognise they don't live on the wrong side of town in the low-spec social housing over there. The idea that you can have the same ladders of opportunity, that you can integrate affordable with private homes and have the same access to jobs, training and so forth, but also the standards—standards in terms of quality of the house and how you feel about yourself and where grow up. It's a hard thing to define, but, I think, as I say, it's really quite important to young people, their aspirations and their attainment, to make the most of their life and opportunities that we hope are afforded to them. 

On standards here, also, it's about economies of scale. You have Government subsidy or registered providers here in the UK that would otherwise be drawing money from the private sector alongside the subsidy, and they have real buying power, so they should be able to look through their supply chains and when you find standards improve, you'll find those costs come down. Otherwise, if you're looking to just keep the costs down because someone's claiming viability, it becomes a race to the bottom, and standards drop, and I would be concerned if social housing standards dropped far behind private house building, because invariably it's the same house builder that's building, and therefore they should be able to realise economies of scale in the delivery of those schemes, assuming they deliver integrated schemes, which is very much what the Duchy espouses to do.

And the other point, just to add on quality, is the pound to square foot you referenced is really interesting. We deliver quality with private SME house builders, so Cornish builders in Cornwall, Dorset builders in Dorset, and not the volume PLC house builders who have larger overheads and deliver lesser quality for the same price. So, we feel like we run a tight ship, we deliver quality efficiently, and why shouldn't people on the lowest incomes benefit from lower bills from thermally efficient, highly insulated, more sustainable housing?


I ba raddau mae seilwaith cyfleustodau yn ddigonol i gefnogi adeiladu tai? Mae Avril wedi sôn rhywfaint am hyn yn barod.

To what extent is utilities infrastructure adequate to support house building? Avril has touched on this already.

Would you have anything to add, Avril, to what you said initially?

Yes, so I think the only other point that I would make is the phosphates issue, which we know is still a massive issue. If you take Powys as an example, half of that county still has effectively got a ban—not a a technical ban—on development. It just can't happen because there's still no solution for this issue. So, actually, an update on the plan to fix the phosphates issue and invest in that infrastructure—I don't think we've had an update since 2023, and so actually some sort of gusto behind that to actually think, ‘How are we going to deal with phosphates?’ Again, there might not be a solution, but, actually, if we can invest in infrastructure that would clean the phosphates before they enter the water courses, then, actually, that would be a step in the right direction. But at the moment the uncertainty is just killing off any ambition for development. That's the only other infrastructure that I would raise today. 

Have events taken place in this area as far as you're aware, Avril? Because we've heard from the Minister that she's been bringing the main players together to try and find an effective way through. 

So, we've been involved in some; I would say that there's still no clear pathway. I think we can all sit around a table and talk about the issue, but, actually, without a commitment on what's going to happen, where do we go from that? Yes, there have been events, we've heard the Minister saying she's going to events, but, again, no update on the actual plan.

Ac yn olaf gen i, felly, mae'r cwestiwn yma ynglŷn â defnyddio'r adeiladau sydd gennym ni yn barod yn hytrach nag adeiladu adeiladau newydd. Oes angen gwneud mwy i gefnogi caffael ac ailfodelu adeiladau presennol?

And finally from me, therefore, there's this question of using existing buildings rather than constructing new builds. Does more need to be done to support the acquisition and remodelling of existing buildings?

So, it's one part of the puzzle, and I think we would question what cost to acquire existing buildings, if that was being done by local government, for example, and where are they getting the resource to do that acquisition? If we're talking compulsory purchase, it takes a very long time and can be a very, very costly process. However, we would support the remodelling of existing buildings through incentives. So, actually, if we're if we're talking about upgrading, for example, energy efficiency measures, and making those homes of a higher standard for anyone, whether that's private sector or within the affordable or social sectors, then that's absolutely something we would support. We think some of the incentives can be through the tax system, and I appreciate that that's difficult for Welsh Government to do on their own. It would take co-operation from Westminster, but, for example, the zero rating on energy saving materials doesn't apply if you're doing it yourself, so you have to employ a contractor. So, actually, quite a lot of our members might have an in-house team that can do works to their properties, but they don't benefit from that zero rating on energy saving materials because they're buying the material themselves. So, some sort of push to Westminster to amend that would be of use. 

Secondly, we've got an issue in rural areas with how much these properties can actually be upgraded to be of a higher standard. So, if you take solid walls, for example, they were built to be breathable, and, actually, the current system of measuring energy performance encourages you to completely make a box out of those buildings and fully insulate them, which can then cause damp and mould issues. And we know of the issues in the social sector of damp and mould, and, actually, do we want to be creating those issues?

So, I think it's some sensitive remodelling of existing buildings through incentivising possibly private owners, possibly the social sector, and then using resource to actually build new. So, yes, it's part of the solution, it's not the only solution. 


Siân, thank you very much. By the way, Ben, do come in whenever you wish to on any of the points. 

Thank you, Chair. I was just going to, really, concur. I think incentives around refurbishing would be interesting. We've been listening to other landlords, because they would sometimes have to refurbish a property at cost and justify that by then upping the rent, which could probably put it back into the private market rather than the social market. We're not talking about the Duchy of Cornwall here, but that's a general point. Thank you, Chair. 

Thank you. Regarding delays in planning and consenting, what improvements do you think could be made to speed it up? 

A big question and it's probably going to be quite a long answer, if you don't mind. So, the CLA does a planning survey, and our most recent one, a couple of months ago, said that 94 per cent of our members who are going through the planning system thought that there was a significant lack of rural knowledge within the planning system. And that's quite a big issue, because if a planner is not understanding the needs of a rural community, how can they make an assessment on a planning application for a rural area? So, I think—. That's not specific to your question, it's not a delay, but if they're pondering because they don't know, then that could cause delays. So, that's issue No. 1.

Both. So, what is a rural area—infrastructure, what jobs might there be in a rural area? We know that rural communities are perhaps sometimes closer. There are difficulties with Nimbyism, more so, perhaps, than in an urban area sometimes, and actually a planner not understanding the sensitivities of the development and why that parcel—. So, we get quite a lot of them saying, 'Well, why can't you bring this parcel of land forward instead?', and, actually, there'll be a lot of background as to why that parcel of land might not be brought forward. But then also there are the needs of a diversified rural business. So, an urban planner with an urban background might understand farming because it's what farming looks like—you drive a tractor, you're on a farm—but, actually, what diversified businesses need might be how that translates into their development needs as well. So, that's the issue with understanding rural. 

Secondly, there's the amount of houses that have been delivered in Wales, and you can tie this back to the planning system because although the permissions might be given, actually, the build-out rate has been low. I think it's about 30 per cent over 20 years decline in housing delivery in Wales. So, we're just not building the quantum of houses that we need.

The difficulties with planning and adopting a local development plan—again, I'm sure you've heard this before, but, I think, when I checked yesterday, there were only four local development plans in Wales that were in date and did not need review. So, there were some that were in date but needed review on what needed to be delivered. So, four out of, I think, 24 local development plans across Wales is not a particularly good percentage. 

So, how can we solve this? I think resourcing is a big issue. We've called for two extra planning officers in every county or every local planning authority in Wales, at a cost of, I think, £6.2 million over the next five years. It'd be great if those were rural planners, and most counties in Wales obviously have rural areas, so it'd be great if they could be fully trained on really specific issues.

And then, secondly, with resourcing, there's obviously putting more people in, but then there's also taking off some of the strain. We're not saying fewer planning applications and fewer houses being delivered, but, actually, what we think is lacking in Wales is a system of permitted development rights. So, we know these have been hugely successful in England. They've allowed farms to diversify. They've allowed—. There have been some issues in urban areas with office conversions, but, actually—. So, class Q, in England, which is the conversion of agricultural buildings to dwellings, has been hugely successful in providing more houses for rural areas. And, actually, that takes off some of the strain from planning authorities. So, a common misconception with permitted development rights is that it doesn't require any involvement from the planners. That's not true, there is always an element of prior approval, so planners do still have some control back. So, you're taking out a lot of that resource strain, opening up the resource to approve more, bigger sites. So, yes, I think I'll stop there on planning because I could talk about planning for hours. [Laughter.] But I'm sure Ben's got a lot to say as well.


Thank you. I certainly concur on resource for local planning authorities, which have been stretched. And then I was just thinking on the shift back to strengthening the need for having a valid local plan, and how the numbers are to be set, in terms of meeting local needs. And then the strengthening of rural exception sites, which is not quite like a permitted development site, but the idea that, obviously, if you can streamline the planning system for those people that are meeting the core criteria you wish to see—and that minimum 50 per cent social housing, for example, I think is certainly—. Down here in Cornwall, we'd want to see—. I know that Cornwall Council want to see 100 per cent, but it's a minimum 50 per cent for a rural exception site.

And we have here in Nansledan something that's not been utilised much, actually, in England or Wales, certainly not on private land—we have a local development order. And Cornwall Council basically said, 'We would rather plough our resources to raise the standards of some of the other applications coming through. And every time you go through an iteration of your scheme, you have to come back to planning, which is, frankly, costing you money and fees and us time and resource.' So, the local development order is a very flexible planning consent, to build these 4,000 homes, because our standards are higher than the minimum policy requirements. But as long as we're delivering certain criteria, it's basically saying, 'You can have the flexibility of that consent because your standards are higher', and that can be in terms of social impact as much as quality and sustainability more generally. And I think, if you can find a way of holding a developer's or landowner's feet to the fire over that—. And, of course, you can withdraw it if they're not performing. And so Cornwall Council audit us and we certify things in accordance with—. But it's empowering from the landowner's perspective, it gives confidence to the market to invest and deliver, and it's not actually taking away the powers of the local planning authority—they can come in and revoke this at any moment. And I just think, actually, it's a really interesting planning tool, in the right hands.

Is there anything else you'd like to add about bringing forwards rural exception sites and how this could be supported?

Yes. So, rural exception sites have been a big drive for the CLA. As Ben said, there's a huge untapped potential there. The first thing I'd like to say, though, is that the PPW that was issued in February 2024 has no reference to rural exception sites—it's been removed. It doesn't mean rural exception sites don't exist in Wales anymore, but even just what does that say to the people that perhaps want to bring forward rural exception sites. Affordable housing exception sites are still referenced in there—

'Planning Policy Wales', yes, sorry. So, the removal of any reference to rural exception sites was a bit of a surprise, to be honest. So, in support of rural exception sites, the CLA has developed the planning passport. One of Ben's colleagues fed into that. And the CLA talked to housing associations, we talked to local authorities, national parks, private landowners, about what are the difficulties with delivering on rural exception sites. And the two main themes that came out were the resourcing of planning authorities and the cost of a planning application. And then, when we were talking to communities, and landowners as well, the issue was the reassurance that those homes are going to be affordable in perpetuity, and that they're not going to be built and then have one generation of affordable and then be sold, particularly in those sorts of areas where high property values are such an issue for rural communities.

So, we looked at existing planning structures that exist. So, we looked at local development orders, we looked at permission in principle, which is a two-stage process, and we looked at permitted development rights, and we said, 'What can be drawn from all of those planning processes and applied to rural exceptions sites specifically, to enable their greater use?'

What we landed on, after a lot of consultation with all those players, was a two-stage process called the planning passport. Using, primarily, permission in principle as its base, you have a stage 1 application, which sets out the quantum of the homes to be delivered, the tenure of those homes, an element of what community engagement have you done to get there, and the setting of that site. That's quite a low bar to jump over. So, again, investment in that site at a very early stage is limited. You go to the planning authority with that stage 1 application and they say yes or no, or, 'Amend it in this way'. Again, it also takes elements of a pre-app, but because it's a stage 1 application with a permission in principle, it's legally binding, which a pre-app is not. Once you've got that stage 1, that gives whoever's developing the homes, and the community, reassurance that they can spend the extra money on the stage 2.

The stage 2 is then the technical detail, so that's all of your highways assessments, your refuge, your window design, all of the things that you would expect of a normal planning application, but with restrictions. Because some of the feedback we also got was that perhaps there's a delaying tactic by authorities, perhaps for lack of knowledge, and worry of not collecting all of the right information. Planners can often ask for a vast list of information that perhaps isn't needed. So, again, the planning passport is quite rigid in what you will be expected to provide. Again, that helps with justifying the investment and knowing how much you're going to have to spend on that application.

Once the technical details consent stage has been approved, then you can get on and build the homes. So, again, everyone knows—the developer knows, the community knows, the planners know—what's going to be delivered and how much it's going to cost them, how long it's going to take. So, that's why we developed the planning passport. We think it can be done through a statutory instrument. We think the framework is already there in PPW. We just need to get some momentum behind it. But we know it'll be used. We did a mini-survey of the people that we'd consulted, and just on base numbers of their development goals, or, if they're landowners, the land that they can provide, we think it would increase rural exception site delivery by three times, which would be a big contribution to social or affordable housing delivery.


Highways is often such a big issue, so if an application was granted before highways officers actually fed into it, I'm a bit concerned about how that would work, really.

So, it's not the permission itself. So, of course, you could get to stage 2 and you could still get a refusal, or the highways could still say, 'Okay, well, you need to amend it slightly'. I'm perhaps speaking out of turn about some people that have put forward sites, but highways can be an issue when you've spent vast amounts of sums on everything else. And we've got to trust that planners will have an idea of a site; that's what a planner's there for, and that's why we're talking about setting. So, is it well related to the development, is there a main road or is it a single bypass—it's all those kinds of things that you would look at at stage 1, to limit how much the technical details could say 'no'. But the point is you're giving reassurance that the planners aren't going to say 'no' on the basis of there isn't affordable housing need, the community hasn't been consulted—that's the key that we're trying to address.

Diolch, Cadeirydd. The Welsh Government own an awful lot of land around the country. I'm just interested in what you think the guiding principles for the Welsh Government should be around publicly owned land. I'd be interested to hear your thoughts, and obviously Ben's thoughts with England as well, what the UK Government's guiding principle should be with their own land. I'm sure you've had to deal with them when you've been dealing with matters concerning His Majesty the King, so I'd be interested. Avril, probably, to start, if that's okay. Thank you.

My previous job was doing affordable housing development. I was doing the land-buying early stages in the planning application stage, and quite often—this was in England—there'd be a police station that's not used anymore come up for sale and we were always outbid because there are valuation and maximising value principles with publicly owned land. That's not necessarily a bad thing, but when you're trying to deliver affordable housing on those sites, you're always going to be outbid by the private sector.

I think there should be a reset with what maximising value for a local authority or for the Welsh Government means. Affordable housing provides a lot of value that might not be financial, but, actually, if you're the Welsh Government, what more value can you get than providing more affordable housing to clear your housing waiting lists? Of course you need to get financial value as well, but just looking at the balance rather than just going for the highest bidder.

I think they should also be looking at who the landowners are surrounding that land. Are there opportunities to offer the local landowners the opportunity to purchase that land? They might have another site next to it that they want to develop, but actually, to make it viable to deliver their site they might want to do an element of land pooling with the Welsh Government. So, actually just making an assessment of the surrounding areas as well rather than looking at the parcel of land in its own right.


It's interesting to hear Avril. I was area manager for the south-west for Homes England for a year before I joined the Duchy, and I was working in the Olympic park in London before that, but I fought tooth and nail to set a criteria based on quality as much as price. At that point, George Osborne had made a statement in Parliament about raising £5 billion from surplus public sector land, and that was before we knew what we were going to do with that land. I thought that was very curious, because there was clearly a case and a need always to make the best use of public assets.

In that case, historically, it was best value. I'm pleased to say that that's no longer the case. With Homes England and the current tenure, they're back to changing the criteria. I had to work really hard to make sure that we were selling the land to the people who would deliver the social impact and to try and set the criteria with strings attached, as it should, for public land. So, I think what I would say to the Welsh Government—as I would to any landowner—is be clear on the criteria, because I know of landowners here in Cornwall and across England who have regretted selling to the highest bidder in areas where they have a vested interest themselves and care about that community, and therefore retain control.

That's the other point: there's always someone sitting on someone else's shoulder telling them to cut corners and maybe not renege on obligations, but maybe to revisit and renegotiate. It's very similar for the Duchy, as I think it is for public agencies and public land, which is, if you can set some clear criteria, which is a commitment to quality outputs, don't be shy of working with private house builders rather than volume PLCs—people who are committed to the same quality outcomes you are. Because that's the other point: often, Homes England were selling to volume house builders. If you retain control through the disposal of land and enable the infrastructure, like we do, you're guaranteeing the quality outputs and the socioeconomic impacts you want to see. By retaining that control, you're turbocharging it through the delivery of infrastructure as well, so you can set quite high and exacting standards in return.

And that's the relationship we have. It's a bit like a patronage is the landowner of the process. I think there's a lot of landowners now wishing to follow suit, building a legacy movement, which His Majesty started, and I'm pleased to say that the Duchy has been at the vanguard of. I'd happily talk in more detail about that if anyone wishes at a future date.

If you could send us some written stuff about that, Ben, that would probably be useful, in the interest of time, if that's okay, Cadeirydd. The next question I want to go on to is the appetite amongst landowners and developers for building social housing and bringing those sites forward. I respect, Ben, that you're in a different position to a lot of people. His Royal Highness the Duke of Cornwall is probably in a different position to a lot of different landowners and developers out there, but do you think, on the whole, there is an appetite within landowners, developers to actually bring these forward? Because what we do hear a lot of is on viability—that when we bring social housing forward, it's not as viable as when we put private housing in. So, I'm just interested to hear your thoughts on that, really. Do we lack that sort of enthusiasm to build social housing?


I genuinely don't think so. Obviously, I can't speak on behalf of all landowners. I think some things are of a theme, and it's remarkable how familiar they are across the country—the UK, I mean. So, as a landowner, often, they know it's a very expensive process, the planning process. It's fraught with difficulty and uncertainty, certainly in recent times. So, you have to have deep pockets just to promote a scheme for development. And what often happens is they renege control and agency of the process, because they might be land rich but cash poor. I honestly can think of many occasions, just in the last few years alone, where landowners have regretted selling their land too early and losing control of the process.

They obviously need to think about why they're selling that land, and often, of course, it would be inheritance and so forth down the line, and maybe their own straitened times, who knows. But I always encourage landowners to not cede control of the process and to be patient about the capital, because there's a greater dividend by staying in the process. I know, you're right—we obviously are a privileged landed estate. It's not mortgaged land, it's land we own, so we start from a position that's more comfortable than perhaps a smaller, say, farm holding where someone is just trying to make ends meet. But I think the cost of the planning process is a concern, infrastructure costs are a concern, and all of these reasons—. And if affordable homes aren't able to cover the build cost, then all these things affect the viability, and the landowner eventually cedes control to maybe a house builder who might not be interested in delivering social.

But I can tell you, just in Cornwall, there's a whole movement. It's called Homes for Cornwall, and it's major landowners who—. Cornwall Council has said, 'Well done for convening—we can't normally engage with these people.' But often it's because they don't want to see poor-quality homes built on their land that don't deliver local needs. They don't feel that they have agency over the process, and they don't have the funding to promote through planning. But if you speak to these landowners, the only way they would want to see productive agricultural land taken out of being agricultural land is if it did deliver local needs. They just don't feel they're empowered in the process, because, to your initial point, I think, you kind of need deep pockets to work through that process yourself.

So, I think greater engagement of landowners and support through planning would lead to better quality outcomes. I genuinely believe that. Because landowners suffer if local people can't afford to live in those areas, because they're the workforce, they're part of that balanced community that they have a vested interest in.

I've not much to add to what Ben said. Of course, there are instances where a landowner feels forced to sell the land to the highest bidder. They might have bills to pay. They might, as Ben said, have inheritance considerations. So, there are cases of that. But I think, no, there's not a lack of enthusiasm at all.

As Ben just said, landowners are also suffering from the housing crisis, particularly in rural areas. We have got members that are trying to expand their business. They can't recruit, not because of a—. In some cases, it's because of a lack of labour, but quite often they'll get a lot of applications for a job, and they actually can't recruit for that job, because then there's no housing available. Again, traditionally, an estate might have houses to offer to workers. Those houses might have, over the years, been put into the private rented sector, they might have been sold off, they might just already be full and, actually, that business is expanding. If those houses aren't there, that really limits that business's ability to grow and be dynamic and survive.

So, there's not a lack of enthusiasm. I think there's, sometimes, a lack of understanding, and that's where the CLA plays a role. One of the things that I've really tried to do since I've been at the CLA is to make landowners aware of things like rural exception site policy and, if they don't want to do it themselves, how to tap into the knowledge that's within housing associations, what community groups might be available to help you to develop. And we do get a lot of member queries on, 'I want to give something back to my community, I want to sustain my community and build some affordable housing, but I just don't know how to do it or I don't have the resource to do it myself.' So, absolutely not a lack of enthusiasm, I think, just that the systems are not in place yet to enable it at a great scale and to realise that enthusiasm.


Okay, thank you. My final question, Cadeirydd. The Welsh Government has announced that it is going to consult on the new compulsory purchase powers under the Levelling-up and Regeneration Act 2023. How should these new powers be used, and should people be cautious about these powers? I'm just interested in what your views on that would be.

Yes, so, completely openly, we fought quite hard to see those powers not introduced. That's the removal of hope value for sites that are for affordable housing, education and healthcare. Again, I said very early on that I think it's a misconception that land value is sometimes the barrier to affordable housing development. Hope value is a concept. It's not necessarily the actual value of the land, so to say you're going to remove it, I think, should be an absolute last resort. Take an example of a farmer that's quite a small farmer, and their land might be in a particularly good place for housing development but for whatever reason they haven't put it forward for private development and it's identified as affordable. If you say to that landowner, 'We're going to purchase your land at agricultural value, but 90 per cent of your farm is going to be purchased,' actually that business doesn't exist anymore. They can't sustain their business with 10 per cent. This is a hypothetical example, of course. But, actually, early engagement with that landowner—and as we've said, there is enthusiasm to see these sites built—early engagement saves the very lengthy, costly process of compulsory purchase, of which hope value is such a small part. You've got surveyors' costs, you've got the solicitors' costs, you've got the cost of actually applying to Welsh Ministers to remove the hope value—it's not an automatic removal—and that could take years and years and years, and, actually, at the end process, what damage has been done to that landowner and potentially to that community that are feeling like they're going through a process of compulsory purchase that's been forced upon them?

So, we think, firstly, it should be absolutely a last resort. We recognise that in some cases it might be necessary or deemed as necessary. In which case, we would strongly encourage that there be a duty of care to landowners introduced. So, again, in that example of the farmer that might be losing the majority of their holding, actually there should be a duty of care on Welsh Government to assess what the impact of removing that hope value or even going through the compulsory purchase would be on that landowner. And again, if compulsory purchase is the way forward, and those developments are brought forward, we think there should be rural delivery groups—again, with people from that community, potentially the landowner that's had their land compulsory purchased—so that they can be involved from stage 1 in the development and what's going to happen to the community. They should be independent from the development. They should be people from within the community that understand the impact that these sites are going to have on the community, particularly if they're large sites, which we think they possibly will be. If you're going through the process of compulsory purchase, then you would hope that it was a large site that warranted the cost of that. So, yes, a last resort, if it's necessary, rural delivery groups and a duty of care to landowners.

Okay. I did say that was my last question, but something else has popped into my head now, so, unfortunately, you're going to have to field another question. We hear anecdotally—and I know it even from my own constituency, which is in Powys—that some people do do a bit of land banking as well. Some of the big developers will buy a parcel of land and put a bit of entrance way in, and then they'll sit on it and they'll hold it and hold it until land values have gone through the roof, and then they'll sell it, which is their own right. But when we do have a massive housing crisis across the country, do you think there should be an element of—and I probably can prejudge your answer—a bit of 'use it or lose it', you know, 'You've got to get this site developed within a certain amount of time or you're going to lose your planning permission or removal from local development plans'? Because, I think sometimes it is wrong that people put in for planning, go through the process, get the planning permissions on it, when I've got communities—and I'm sure Siân will have them in her own patch—that are desperate for housing but the sites will just sit for years and years under LDPs, UDPs, and they keep coming back around and around again, and nothing is done with them. So, do you think there should be an element of: if you don't use these sites and get them developed then you're not going to have planning on them in the future?

So, the CLA is probably not the best person to comment on that. 

We obviously represent landowners rather than—


—rather than the big developers. I think we need to look at why those permissions aren't being built out. Is it because they are assuming that land values are going to go up or is it because the permission is not able to be built out at that time? There are systems in place that you can put in through a planning permission—a planning permission does expire, it's not—

But if you put an access way in, the planning permission has started.

But you can have—. But there can still be milestones that need to be met through a planning process. So, that is still possible. So, it is already possible. Yes, it's a difficult one for us to comment on, because, usually, our members won't be involved after the land has been sold, and, if they are, then they don't want to see their land not being developed, particularly if the value is tied into the houses being sold—they don't want to see them not being developed either, because they're not getting the income. But, yes, I would defer to somebody like a property federation that's representing big developers.

No, that's fine, I just wanted to see—. That's fine. Thank you; diolch.

Yes, if I can go back to both of those, then, I think, on CPOs, to start from afresh there, I concur. I was involved—. I worked on the Olympic park, on the largest CPO that was ever undertaken in terms of the relocation of 2,000 businesses and residents from what is now the Queen Elizabeth Olympic Park. Within the primary Act—the London Olympic Games and Paralympic Games Act 2006—with all the political will in the world, it was £1.1 billion of the £8.5 billion budget that went on the land acquisition and the relocation of those businesses. And the only good excuse for having a modern-day Olympiad, by the way, is to regenerate a piece of city, so I'm not criticising the process at all, but reflecting on the 'proceed with caution' point. I'm sure that, strategically, there are times when CPOs are necessary, but, if you can resolve things by private treaty, inevitably it will be more efficient. So, I think you have to be cautious about utilising them, because property rights go back to the Magna Carta, people will appeal decisions along the way. We were lucky in that regard—we had the general vesting declaration with a cut-off date—but it's still a last resort.

I think—. Linked to that was this reference to hope value. I think it's an interesting one, and I would say that that is a case of 'don't throw the baby out with the bathwater'. And by that, I mean, when you consider what the Duchy does and what we espouse and promote and encourage other landowners to do, it is to forgo land receipts and reinvest them into creating that quality of place and social infrastructure. And frankly, if that wasn't there, we wouldn't do it. We aren't a charity and we are aiming to deliver a return out of Nansledan, and I mentioned the 15 years of patient capital before we break even in 2032. The Duchy would not do this at all if the suggestion was—. It's almost like a, you know, 'The market is broken, therefore, we'll try and take the money away from the landowner', and I just think it's the wrong approach. I think we're always better to go with incentivising social impact and quality, and that means taking landowners and the market with us and so forth. I think you just get better outcomes more efficiently. So, I would also be very concerned about hope value, because what we're trying to say is that it's not just about extracting value from private housing and delivering social over there; we're trying to deliver the whole balanced community in one and recycling land receipts to do that and our own money as well. And that land stewardship model would disappear, basically, if hope value was rolled out everywhere.

But I think land banking—. It never goes away, does it, and maybe there are some people with a low cost of capital that do, but I always find it intriguing because, when you think about the cost of purchasing land and getting planning, there's normally a cost of finance attached to that, unless people are cash-rich, so it should be burning a hole in their pocket. If it's public sector land, absolutely, I think you have to show your teeth probably, but the use-it-or-lose-it point, I wasn't aware of what the time frames are, but ordinarily you've got to have a meaningful start on site, haven't you, after three to five years, so you do lose the consent and you have to reapply. So, I'm kind of—. I've been in this industry a little while now and I honestly don't see many examples of it, but then I don't work in a volume house builder environment. I'm sorry, I'm not giving a clear answer to the points, but I'm not sure there is one.


No. Okay, Ben. We will move on to Altaf. Altaf Hussain.

Thank you very much. Good morning. I think we've passed 11:10, so it might take another five, 10 minutes, really. Now, my area of questioning is about communities. We know building trust and open communication are lacking when we talk about social and affordable housing. So, my question is: how can communities be effectively engaged in social housing developments in their areas? What good practice are you aware of in building local support for new developments?

Thank you. I'll happily talk about our process. What is now the King's Foundation—it was the Prince's Foundation, but, basically, it's a charitable arm of our former Prince of Wales and Duke of Cornwall. They were then the Prince's Foundation for Building Community, and they helped us engage the community early on in what was called an enquiry by design. It actually came from a new urbanism movement in America, and you definitely, in all my experiences—. I did also adopt something similar for—[Inaudible.]—under Homes England. It is about preparing and understanding the context, literally the lie of the land and maybe all of the surveys I think they've done around that. So, then you run a process that might be over a long weekend, for example. You invite everyone, and I mean all the stakeholders, and that can include statutory consultees, obviously the local authority, but very much the community at large themselves. That is to identify what the needs are, what they like about their local area, what they don't like and what social infrastructure is required. Also, you genuinely get better quality outcomes and better quality design, because they know better than everyone about whether—'That survey might say this, but we know that field floods', or whatever it is. It's a real collegiate and collaborative process, and you get that buy-in, and they tell you if they want a modern aesthetic or to retain some local style and architecture. I think it provides a bit of momentum, as much as it requires some upfront resource.

We've always done it. For Poundbury, there was a charrette—the Prince of Wales turned up; it was called a design charrette—over a weekend. We had, as I've mentioned, the 2005 enquiry of design here in Newquay. I think if there's maybe Government support through that process, and whether or not that leads to a design guide, a sort of pattern book, something that you can then take to market and say, 'This has got local buy-in,' and actually that carries weight through the planning process, then, hopefully, it just gives a better chance of that vision being delivered.

I would just agree with what Ben has said. I think we've possibly all been to the sort of placard event that's called community engagement, where the scheme's already been designed and then you say, 'What do you think? Do you want it? Yes or no?' The answer inevitably is always 'no', and it sometimes happens anyway, because they haven't been involved, the community hasn't been involved, early on.

The CLA's been involved in a project to produce a rural good design guide, which is launching on 5 July, which is actually Rural Housing Week, I think only in England, but you should have it in Wales as well. Rural Housing Week is the first week of July. That rural good design guide is looking at, actually, not just what is beautiful, because that varies in every community and what's already in the community and what the community wants, but actually principles of things like indoor/outdoor living, which are quite often forgotten in new builds, meeting space standards and community engagement, because that's such a key principle of good design. So, we'd be happy to share that guide once it's been published. But, yes, it's definitely looking at—. It's applicable to anywhere in the country—it could be down in Cornwall, it could be up in Yorkshire, it could be in Powys, it could be in Cardiff. It's looking at what are the principles of design that are not locally specific. So, yes, I think there's definitely—. Communities play a huge role in what is designed.

Thank you very much. My last question is: in reality, what role could community-led housing play in addressing the shortage of social homes? Do you think it will keep housing costs low, below 35 per cent of the household income, that it will meet the local needs and that it could be made elderly people-friendly, as we have an ageing population, and that it will create a sense of community? Thank you. 


Community-led housing comes in all forms. I think some of our members would like us to say that if housing is being brought forward by a landowner in collaboration with the community, then it's community led. But, if we think about the sort of more usual structures, things like community land trusts, absolutely, they can play a role. I think there's a concern with their financing, particularly if they are, essentially, a start-up; they have no access to assets—it's quite often the case. They might have a landowner that's sitting within their group that has access to the land, but, actually, you have to keep those things very separate to make sure that there aren't conflicts of interest. And finding people with the time within a community who want to put in the time and effort and have the skills to do that, and then can find that finance to do so, is a big barrier. There used to be community land trust funding in Wales. I think that's gone, for, probably, obvious reasons. But, actually, having some form of low-cost borrowing so that those trusts or those community-led groups can get themselves set up—.

There's also a role for rural housing enablers to play in setting up community-led housing. Again, if you're a community-led group that doesn't, perhaps, have planning expertise and doesn't have expertise on accounting, which are, obviously, key principles if you want to deliver housing, then a rural housing enabler can either provide that expertise themselves—it's quite often the case with planning—or they can put those groups in touch with, for example, housing associations or local government, which do have that knowledge. But, again, rural housing enablers' funding has been cut or has gone, so they're not in every area. So, we would like to see, to enable more community-led housing, rural housing enablers better funded, and better access to finance.

Yes, thank you. I think it's a fascinating one, and thinking about this—[Inaudible.]—from the Olympic park to Homes England, but I think community land trusts in rural areas are really interesting. I mean, you're basically saying, for example, 'This is a rural exception site that we wouldn't approve for housing if it wasn't delivering local needs and guaranteeing affordability in perpetuity, therefore, why not lock it into a community land trust, where the underlying freehold is owned by the community?' and where there wouldn't necessarily be a registered provider for the housing already in place. I think, also, though, to echo the concern, if you're pushing an open door and this is something that the community wants, great, go for it, I would say. On the other hand, sometimes, when they're trying to sort of conjure up, as a concept, something that we all would like to see, but actually, there isn't the community, there isn't capacity and it's another layer of bureaucracy, because you have a willing landowner and you have a registered provider, then let's not get in the way, if there's a more efficient way of delivering.

On the point on the 35 per cent, I wish we could see more of this, because you're entirely right, and this is the nub of the issue: those on the lowest incomes we're trying to deliver truly affordable homes for and we need to find a more efficient way of doing it. I mean, that's really what you're asking. And the only example I've found recently was with Centrepoint in London, and we're looking to work with them where we're going to lease them a building for 60 years and they refurbish it—it used to be, formerly, nurses' accommodation and it's surplus to NHS requirements—and they will guarantee that they won't charge more than 30 per cent of that young person's income. These are young people coming out of care, and they could be in apprenticeships, they could be in employment. But I don't think, without that—they've got, basically, philanthropic funding from the Tetra Pak family for this—it would stack up financially, because you don't know what those people's incomes are. So, it really needs subsidy to guarantee a 30 to 35 per cent max of rent—as in, rent pegged to 30-35 per cent of your income. But, that's where we could help get people out of poverty and housing insecurity.

So, from the Duchy's point of view, we have covenant controls on our land, which is equivalent control, like a CLT. I think the point is that we don't want to give our land away for free unless we know it's going to social housing and will stay as social housing in perpetuity, otherwise what's the point? And it may be one for another time, but anything that's co-housing or community led has got a better chance of openly delivering on the local needs of that community. So, I would support it. It's just always trying to find what the most efficient delivery mechanism is.


Okay, Ben. Thank you very much. Diolch yn fawr. Thank you very much to both of you, Ben and Avril. You will be sent a transcript to check for factual accuracy in the usual way. Diolch yn fawr. Thanks for giving evidence today.

Thank you very much.

Gohiriwyd y cyfarfod rhwng 11:25 a 11:33.

The meeting adjourned between 11:25 and 11:33.

4. Cyflenwad tai cymdeithasol: Sesiwn dystiolaeth 8
4. Social housing supply: Evidence session 8

Item 4 on our agenda today is evidence session 8 on social housing supply. I'm very pleased to welcome Alicja Zalesinska, chief executive of Tai Pawb, Elizabeth Taylor, engagement and policy officer with TPAS Cymru, Debbie Thomas, head of policy and communications Wales with Crisis, and Casey Edwards, project manager for Cwmpas. Welcome to you all. Thanks for coming in to give evidence to committee today. Perhaps I might begin, then, with a question on measuring housing need, and that is: how effective are the current methods of measuring housing need, both nationally and locally? By the way, don't feel that you all have to speak on any particular question. If you want to add something to what's already been said, fine, but not otherwise. Who'd like to start?

Shall I start?

I suppose, in terms of the local measurement of housing need, I think we have seen a lot of improvement, certainly in terms of guidance and, perhaps, the current LHMAs coming out. I think, specifically, because our organsiation deals with equality and diversity, there's much more focus on diverse needs, specifically overcrowding, accessible housing, the needs of disabled people. But I suppose the proof will be in the pudding, on the impact of those assessments. A key barrier, I think, locally, and nationally actually, is data and evidence, and, in terms of the diverse needs of people, accessible housing and disabled people and the housing needs of disabled people, I think, are key examples there. The best practice, I think, local authority or common housing register that we know, in terms of their knowledge of the accessibility of social housing stock locally, is at about 50 per cent of the stock where they're able to say to what extent it is accessible or not, which homes are wheelchair accessible, which ones are, I don't know, perhaps, level 3 accessibility. So, I think that, really, needs to improve both locally and nationally.

And, I'll finish now, but, nationally, I think we need a much better reflection on the more granular and diverse housing needs of the population, better evidence, for example, in terms of disabled people. We've got an ageing population. We know these accessibility requirements, going forward, will increase; they are increasing. But we don't know, first of all, what housing we have in terms of accessibility and what housing we need, what the needs of the population are. There are some good examples. In England, for example, they're able to do that, and I'm sure other colleagues before mentioned the housing survey. I think that would allow us to do that.


If you don't mind me coming in there as well, I'd agree with what's been said, but I'd also add to it that, from our perspective, the 20,000 homes is a great target, but it's not just about building 20,000 homes or creating 20,000 social homes. It's about creating the right homes in the right place, because that's the way you're going to end homelessness and make sure that you don't get people looping back through the system, because they've been placed somewhere completely unsuitable for them. So, I'm really glad that you asked this question, because it's completely key. For me, though, the question does come a little bit early, because, actually, there are a lot of references in various guidance. So, it's really great that we've got the national development framework, policy 7 within that highlighting affordable housing, and you've got references in rapid rehousing transition planning guidance and LHMA guidance all talking about linking those data sets together and joining it all together. But some of those things are quite early on. So, we've just had those templates come through on LHMAs; we've only just in March had local authorities submit those. So, the proof will be in the pudding. And, I think, there are some key things to look out for to see how effectively those do connect.

So, there's a piece of work that's going to start very soon. It's a sub-group of the ending homelessness national advisory board, which is very specifically going to do a deep-dive into three local authority areas and have a look at, basically, how all of these things are mapping out, what homelessness needs are in a local area, and how effectively those things are bringing that all together and putting it through into supply. So, I think that's one thing to look out for. We've obviously got the Audit Wales report coming out as well. And it will be really, really, important to have a look at how those new LHMA templates have come across as well. I mean, anecdotally, I've heard that engagement has been very variable across different local authorities. So, yes, it's really important that we take all of those findings on board and make sure that those documents are appropriately talking to each other, and with any learnings that can make them talk to each other better, to get the right housing at the end of it. 

Jut echoing, really, what colleagues are saying, I think the guidance itself says that the local housing market assessments are designed to give broad, long-run estimates. So, that current assessment is, obviously, not really reflecting the actual need within the community. And, just building on what Alicja was saying in terms of the diverse communities, I think you could add Welsh-speaking communities to that list of the need that's not being reflected as well. So, I think we do welcome the guidance and things like that, but I don't think it's currently reflecting—. Because it's done at that postcode level, sometimes, obviously, the wealthier residents can perhaps skew the data, for example.


I would obviously agree with the other members, and just to mention that a key part of our work is to gather that insight from tenants from across the entirety of Wales. So, we've done that in gathering this evidence today, and one of the main factors mentioned was how children living with their parents are missed out within the current guidance, and they're going unnoticed, potentially needing their own home. Particular examples are people with children with disabilities who are essentially being forced to make their child homeless, evicting their own child, so that they can find a home, so that they can be put on the waiting list, otherwise they're not even given that opportunity. So, there are many challenges still.

Diolch. Ydych chi'n meddwl, felly, fod yna rai setiau o ddata sydd ddim yn cael eu cynnwys ar hyn o bryd, a beth ydy'r mathau eraill o ddata neu fewnwelediad y dylai awdurdodau lleol fod yn eu defnyddio wrth asesu'r angen am dai? Rydyn ni wedi clywed mewn sesiwn yn gynharach sôn am yr English housing survey. Oes angen hwnna yng Nghymru, neu ydy'r arolygon mwy lleol yma yn mynd i fod yn cyfarch ac yn canfod y wybodaeth sydd ei hangen?

Thank you. Do you think, therefore, that there are some sets of data that aren't currently included, and what are the other types of data or insights that local authorities should be using when assessing housing need? We've heard in a previous session today about the English housing survey. Is that needed in Wales, or are the more local surveys going to be meeting and finding the information that's needed?

Could I come in, because I mentioned it before? Thank you for your question. I think it's absolutely needed. We need that data, both locally and nationally. Obviously, nationally, there is a need for a strategy on how we will meet people's housing needs, and I think, Debbie, you're absolutely right in saying that the 20,000 homes targets—it's great to have targets, but in itself it's a little bit crude, isn't it? We need to know, for example, how many wheelchair accessible homes we have across Wales. We need to know what the population need is for those homes going forward into the next however many years, and build according to that, and structure grants, planning processes, and so on, and engagement, according to that. They are able to do that in England, so there are strategies that have that level of detail. And I know that, for example, Welsh Government started monitoring, for example, as part of the 20,000 target, how many of those homes are wheelchair accessible, so it's a great start, but we really need to build on that.

I agree, we definitely need to build on it. I think our data in Wales is not as strong as it is elsewhere in Great Britain on homelessness and housing, and—it links entirely to that first question—it's so important in informing what supply we need and what direction we go in.

I think we mentioned about some of the existing guidance highlighting homelessness, highlighting data that needs to be collected. There's a lot of good information that it asks for in the rapid rehousing transition guidance, but it doesn't necessarily cover everything. So, we know, for example, that there are gaps in our supply in one-bed properties, there are gaps in terms of larger properties. A lot of ethnic minority populations require larger houses, and they're often really hard to come by. And, as has been said as well, accessible properties are really difficult to come by too. So, I think it would be really helpful if we were looking at some data around age, household size and disabilities, among other protected characteristics as well, and feeding that data through more. 

Some of these findings, again, will hopefully come through some of that work that I talked about in the first question, and inform what other areas of data we need, but the other thing I would say is that I'm really grateful to have been invited—Crisis have been invited—to sit on a new group. I think it was last week, actually, it met for the first time, advising on how data around housing and homelessness in Wales can be more granular and look at an individual level, and I think that would be really important. And marrying all those things up and feeding it through to supply planning is crucial.

Yes, it is. 

I would agree with both Debbie and Alicja. I think that it's about getting that right balance between that scientific approach and hearing those lived experiences as well. There needs to be that balance between the qualitative and quantitative data, so that we can really, truly understand that tenant experience. I would point you towards our 'Homelessness Allocations' White Paper tenant pulse survey, which goes into detail about the lived experiences of people facing homelessness.

The housing needs assessment tells us that we need those bigger homes, as Debbie mentioned, and then we're hearing that we need more single homes, but we're finding that people are struggling to allocate certain properties to people, like one-bedroomed properties, two-bedroomed properties, when they're second-floor apartments, for instance. Certain policies in different local authorities would permit a young child to live in a second-floor apartment, for instance, and the age of that child—eight and above is currently what that says—and that's really limiting the accessibility of those two-bedroomed properties that are on the second floor. So, I think it's just about understanding the need and understanding what tenants actually want as well as balancing that expectation.


Yes, I think, just building on what everyone has said already, a really effective method that we've found is working with rural housing enablers in, obviously, those rural housing areas to really understand that need at a micro level. So, obviously, I work with community groups who are wanting to develop homes for themselves, so they will often work with those rural housing enablers and not just survey the population, but host events and drop in. So, again, like Elizabeth was saying, you can have those lived experiences, and also you can really target not just geographic communities, but also communities of interest as well.

So, we're working with a group in Cardiff, an LGBTQ+ group, who are currently setting up a housing co-op, and they've actually surveyed people within their own community to help to understand their housing need from their perspective, not just on—like Elizabeth was saying—that scientific level. And there's also another group in Cardiff as well of Muslim women from the black and minority ethnic community, who are trying to understand the housing need within their community as well, and then working to address that need.

So, I think that that sort of method of really getting to know your local area and working with those people—. Because we've heard anecdotally as well that people like the children living at home with their parents, they might not actually see themselves in housing need, and so wouldn't necessarily come forward for the official housing registers and that kind of thing. So, I think when you do it on a community level, you really get to understand that local housing need, and then hopefully you can work to meet that need then.

I can remember when we were desperate for bungalows in our village, and then the planning officers said, ‘Well, unless I've got it down as need, and criteria, you can't have them’, and I was like, ‘I know there is a need’, and we didn't have a rural housing enabler. It just reminded me of it.

So, just regarding delivery, how should we manage the need to build one-bedroomed homes with the need to ensure mixed communities? So, not just loads of one-bedroomed homes, but mixed tenure. And to what extent should the acquisition of existing properties be part of the solution to increasing social housing supply? So, we've had the transitional accommodation capital funding programme, haven’t we, which has been really good.

I'm really glad that you put those questions together, because I think they absolutely go together. I think one-bed properties are an issue, but as we highlighted in the first question, there are other issues as well and other types of properties that we need too. I think in terms of making sure that we haven't just got clumps of one-bed properties, the answer to that is actually that it's not just about building new social homes. It is about building new social homes—that’s a massive part of it—but it's not just about that, because that takes time. It takes a lot of time, and actually we've got a massive crisis on our hands at the moment. We've got escalating numbers of people living in unsuitable temporary accommodation. It's damaging their mental health just being there for so long. So, as much as we need to plough that investment into building new homes, we also need to look at acquisitions, absolutely, and other levers as well—so, conversion, third-party lets, all sorts of different ways to bring more social homes through. I think, by doing that, you automatically address that issue of spread as well, because if you're looking at pulling social homes onto the books, not just from new builds, but from acquisition, then that helps to address that problem.

I think what is needed in that diversity is making sure that we have the planning levers that we need to make that work effectively. There are lots of innovative and exciting things that can be done. There's a playbook that the Housing Festival created on modern construction methods, and they've put together lots of good practice. So, things like packaging up small bits of land that no-one wants, those tiny little bits of land across the communities, and packaging those up for developers. There are lots of good examples in that playbook that can be taken on board.

But I think, also, there are some levers that potentially we're not using to their full ability. So, section 106 has massive potential to add to our affordable housing, but we know from Stats Wales statistics that that money is often not being spent, and we also know that the guidance on section 106 and affordable housing hasn't been updated since 2009. So, something that we'd really like to see is, there's so much to our planning system, we'd really like to see a review and a body specifically looking at how those levers are working through a homelessness lens, how effectively are we using all of the legislation that's there and what needs to change, what guidance would help to make that work better.

And then the last point I was going to say—I'm sorry, I'm hogging lots on this question, but it is an important one to us—is the review of rapid rehousing transition plans as well. So, it's absolutely amazing that we've got rapid rehousing transition plans in place across Wales, but that's still fairly early days. We know our local authorities have been under masses of pressure, and the deadlines for meeting those plans were quite considerably pushed back. And there's still not really been a review of how effectively they are working, and lots of anecdotal evidence of rapid rehousing transition plans not necessarily being bought into by planning departments, alongside housing departments. So, I think there's a lot of work to do there as well on rapid rehousing transition plans. We've got the foundations in place, but there's a lot of work we need to do to make those work, and work properly to get those acquisition plans through that meet the need that we have. 

Elizabeth Taylor 11:52:21