REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP

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REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
REPORT FOR
FAITH IN
AFFORDABLE HOUSING
SCOPING A STRATEGIC PARTNERSHIP

 Housing Justice Cymru funded by the Nationwide Foundation
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
CONTENTS
INTRODUCTION                                         4

SECTION 1 – FAITH IN AFFORDABLE HOUSING WALES
1   EXECUTIVE SUMMARY WALES                           5

2   METHODOLOGY                                       8

3   HOUSING NEED IN WALES
    3.1 Housing demand                                9
    3.2 Future Generations Commissioner               9
    3.3 Housing aspirations of the Government        10

4   THE SUPPLY OF LAND FOR AFFORDABLE HOUSING
    4.1 Background                                   12
    4.2 Land supply for affordable housing           12

5   LAND OPPORTUNUTIES
    5.1 Background                                   15
    5.2 Is the enabled land value for money?         16

6   ENABLING NEW SITES
    6.1 Background                                   17
    6.2 The added value of Housing Justice Cymru     18

7   A STRATEGIC HOUSING PARTNERSHIP FOR
    THE FAITH IN AFFORDABLE HOUSING PROGRAMME
    7.1 Background on a strategic partnership        20
    7.2 The Greater Manchester Housing Partnership   22
    7.3 Rejecting a strategic housing partnership    22
    7.4 Finding the right relationship               23

8   A NEW OPERATING MODEL
    8.1 A new operating model                        25
    8.2 Procurement frameworks in housing            25
    8.3 Identifying framework partners               25
    8.4 Scale and size of the framework              28
    8.5 How long should the framework term be?       29
    8.6 Continuous improvement                       30
    8.7 A self-funded future                         30
    8.8 T
         ime table for implementation               32

9   RECOMMENDATIONS
    9.1 Recommendations for the Welsh Government     34
    9.2 Recommendations for housing associations     34
    9.3 Recommendations for Housing Justice Cymru    35

2   REPORT FOR FAITH IN AFFORDABLE HOUSING
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
SECTION 2 – FAITH IN AFFORDABLE HOUSING ENGLAND
1   BACKGROUND                                                36

2   TRANSFER OF LEARNING FROM WALES TO ENGLAND                37

3   A NEW DIRECTION OF TRAVEL FOR FIAH IN ENGLAND
    3.1 A regional approach                                   39
    3.2 Faith and community led housing in
        Manchester or Birmingham                              39
    3.3 Increasing the provison of housing for
        homeless households                                   41
    3.4 An alternative growth model for FIAH                  42

4   DIRECTION OF TRAVEL ROAD MAP                              44

ANNEX 1     LIST OF PARTICIPANTS                              46
ANNEX 2     DEFINITIONS                                       47

AUTHORS
Mike Owen – Perran Consulting Ltd
Katie Howells – Associate of Perran Consulting ltd
Emily Powell and Caroline O’Flaherty – Partners at Hugh James
Steve Partridge – Savills

                                                     SCOPING A STRATEGIC PARTNERSHIP   3
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
INTRODUCTION
A
         lmost 10 years ago the Archbishop      This report looks at how this work can
         of Canterbury challenged housing     be built upon with an aim of creating more
         associations and churches to         affordable homes for rent with an ever
work together as partners to build more       greater social value.
affordable housing. In doing this he            Section one of this report focuses on
cited their ‘common heritage’. Since the      Wales. Initially the proposal was to develop
Archbishop made this call, the housing        a model for a ‘strategic partnership’
crisis has intensified and the need for       between a limited number of housing
collaboration has never been clearer.         organisations and Housing Justice Cymru.
    Despite the huge efforts made during      After consultation with the Welsh housing
the Covid 19 pandemic to house homeless       sector, the strategy has shifted and a
people, the tensions in the housing system    new style of ‘housing framework’ is now
remain and people are once again sleeping     recommended.
on the streets of England and Wales.            Housing associations and local
    Housing Justice has set out a vision of   authorities will be invited to join an open
a society where everyone has access to        framework, from which a limited number of
a home that truly meets their needs. This     organisations will be chosen to work more
means a secure and genuinely affordable       closely with Housing Justice Cymru.
home, in a neighbourhood where an               Section two of the report looks at
individual can access work and services       England and whether the success of the
that enable them to flourish.                 programme in Wales can be replicated.
    Responding to this challenge, Housing     There are a significant issues to overcome
Justice Cymru has worked with faith groups    before a roll out of the Faith in Affordable
across Wales over the last five years,        Housing model could be implemented in
helping them to turn their underutilised      England. The report makes a number of
land and buildings into 357 new affordable    recommendations on how these hurdles
homes.                                        can be overcome.

4    REPORT FOR FAITH IN AFFORDABLE HOUSING
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
FAITH IN AFFORDABLE
SECTION 1                                     HOUSING WALES
1.0 EXECUTIVE SUMMARY WALES
The initial brief from Housing Justice            In Wales the amount of public land made
Cymru (HJC) was to scope and report on          available for the building of affordable
the potential for a strategic partnership       housing has been steadily reducing.
with Welsh housing associations. After          Wales is now following the pattern in
consultation with stakeholders it became        England with more of the land for building
clear that a strategic partnership was not      affordable housing coming via the planning
the right method to achieve the desired         process or through the open market.
goals. The work then focused on scoping           The land supply enabled by the FiAH
a framework relationship between HJC            programme has frequently been sold at
and Welsh housing associations which            sub market rates and without competition.
could also allow Welsh local authorities        One senior housing association figure in
the opportunity to join. See page 6 for an      Wales described the opportunity to buy
explanation of the difference between a         land pre-market as “very valuable” and
strategic partnership and a framework.          the opportunity to buy discounted land as
                                                “golden”. A Chief Executive of a developing
BACKGROUND ON                                   housing association in England could not
DEMAND AND SUPPLY OF                            remember the last time their organisation
AFFORDABLE HOUSING IN                           had purchased land without competition,
WALES AND THE ROLE OF                           never mind at a discount.
HOUSING JUSTICE CYMRU                             The affordable housing programme that
Housing Justice was established by              they have helped to enable is significant
faith groups to support households              and it saves both housing associations and
and individuals without access to               the Welsh Government money in the lower
accommodation through the provision             land costs reducing the total scheme cost
of emergency housing. Housing Justice           of building new housing.
provides over 170 night shelters in England       The question in Wales is not “is there
and Wales. Housing Justice campaigns            a need for more social housing?” It is,
to end homelessness and for the need            instead, “how can supply increase to match
for more social housing. Many Welsh             the housing need?” All sources of land are
churches have begun to seek solutions for       important. There is a place for large scale
their 4,500 underutilised buildings and         development schemes for social housing,
churches. The Faith in Affordable Housing       but there is a need for small schemes in the
(FiAH) programme was created to convert         heart of existing communities. The FiAH
this over provision of buildings and land       programme should therefore be recognised
into affordable housing for rent. Working       as an important contributor to meeting the
with churches and faith groups of all           Welsh Governments targets on affordable
denominations, the programme worked to          and in particular social rented housing.
make the Christian value of compassion for        The costs of the enabling role played by
the homeless an important factor in any         HJC are currently funded by a grant from
decisions on disposing of surplus land and      the Nationwide Foundation.
buildings.

                                                SCOPING A STRATEGIC PARTNERSHIP               5
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
CONSTRAINTS OF THE
CURRENT OPERATING
MODEL
Stakeholders identified a number
of inefficiencies in the current FiAH
programme. It is mostly based on
small scale sites and HJC works with a
large number of associations and local
authorities across Wales. The model
offers no opportunity for scaling up the
programme by identifying new sites
as there is no income being generated
by HJC. There are no opportunities for
economies of scale and the model locks in                         ▲ An example of a FiAH family house in
additional costs through inefficiency and                            Llantilio Crossenny.
administration.
                                                                  skills, competence and experience, explaining
A NEW ‘FRAMEWORK’                                                 how they will undertake the work, the added
MODEL FOR THE SELECTION                                           value they will bring to the process and
OF DEVELOPMENT                                                    their proposed costs. After consultation
PARTNERS                                                          with partners at Hugh James, Wales leading
To maximise the benefits of the FiAH                              legal specialists, the form of framework is
programme a strategic partnership between                         being proposed and this is set out in Section
Welsh housing associations and HJC, was                           8. This report provides assurance that this
initially considered. However, within the                         framework model can be delivered, that it
housing sector there are a lot of structures                      will meet the expectations of transparency
that are termed ‘strategic partnerships’                          desired by the housing sector and will be
and as a consequence the term carried a                           robust if it is challenged.
lot of baggage. Stakeholders who were                                 Establishing the ‘framework’ proposed
consulted in the drafting of this report                          here will require a competition between
were enthusiastic about the opportunities                         willing housing organisations using the
presented but felt that a ‘strategic                              following two-part assessment process.
partnership’ was not therefore the right
definition for the outcomes desired.                              PART ONE – Assessment of whether an
    The report now recommends the                                 organisation has the skills, competence,
creation of a ‘framework’ to bring the                            resources and experience to deliver the
benefits of working with a narrower group                         proposed programme.
of developers into the FiAH programme.
The framework model was discussed with                            PART TWO – What additional benefits can
Welsh housing associations and received a                         they bring to the programme? Housing
substantial level of support and when asked                       organisations will be asked to offer
all, subject to the expected queries and                          several additional benefits from including
clarifications, expected their organisations                      regeneration training, commitments on
to seriously consider applying.                                   rent, housing management, Housing First1
    Framework tenders are a form of                               or a range of other imaginative offers
competition where different organisations                         that will improve the outcomes from the
submit a tender proposal setting out their                        programme.

1. Housing First- the provision of a stable, independent home along with intensive personalised support and case
    management to homeless people with multiple and complex needs.

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REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
There are a number of inefficiencies
                 in the current system as
     the programme is mostly based on
                         small scale sites.
   The FiAH programme currently works                          that the programme factors in sufficient
exclusively with the regulated housing                         flexibility to allow for some regional or
sector in Wales and it is recommended that                     specialist lots within the tender process.
this continues. Faith stakeholders identified                     In designing a new framework it is
several factors in deciding who they would                     recommended to use the three new
prefer to work with and in particular they                     social housing zones being considered by
focused on the perpetuity of the housing;                      Welsh Government as part of their social
that housing was a core business for the                       housing grant programme. In respect of
provider and (critically) that they were                       the FiAH model, this report recommends
subject to Regulation.                                         that each zone has a minimum of one
   Notwithstanding, the growth of housing                      housing organisation and maximum of two
providers outside of the regulated sector                      organisations and that the total number
in England and the potential financial                         of partners in the framework is no greater
resources they can bring, this report                          than 6.
recommends that for this tender period                            HJC also has identified a strategic aim
HJC continue to work with the Welsh                            of creating more affordable housing for
associations and local authorities who                         young people, who disproportionately
meet the above criteria. It is believed there                  are the group without adequate housing.
are between 30 to 40 regulated housing                         To encourage more provision for this
organisations in Wales which are currently                     group the evaluation assessment for
building or who are planning to build                          the framework should reward those
affordable housing for rent.                                   organisations that propose working
   The total number of homes enabled                           arrangements with specialist providers,
through the FiAH programme to date is                          such as Llamau2, to help meet the housing
357 (includes completions and pipeline                         needs of young people.
schemes) and Section 5 identifies the                             With the right financial support from
potential for a much bigger programme.                         the Welsh Government and the Welsh
It is recommended that the number of                           housing sector it is believed the new
development partners is scaled to match the                    framework model could be operational by
potential programme. It is recommended                         June 2021.

2. Llamau-a specialist charity working with young people and vulnerable women who experience homelessness.

                                                               SCOPING A STRATEGIC PARTNERSHIP                7
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
2. METHODOLOGY
The objective of this report was to explore
the potential for a housing partnership and
consider whether a similar model could
work in England. The scope of this exercise
was to:
• Evaluate the key factors necessary for
    the strategic partnerships to operate
    successfully
• Outline the working structure of a
    strategic partnership model including
    financial and legal considerations around
    procurement, operating model and
    financing models
• Outline a timeline and programme of            ▲ The Bishop of Llandaff visiting new homes
    milestones for establishing the strategic
                                                   in Porth.
    partnership
• Outline a monitoring and evaluation
    framework for the strategic partnerships     This was never intended to be an academic
•   Assess the advantages, benefits and          study and the report moves from testing
    risks of adopting a strategic partnership    a model with stakeholders to designing a
    model                                        model on the basis of their feedback.
• Identify the potential barriers to the           A key feature of this project was to co-
    creation of strategic partnerships and       produce an operational framework with the
    their subsequent implementation and          very stakeholders who would implement it
    operation                                    in practice.
• Consider the issues, lessons and criteria        As the report progressed, interest in the
    necessary to apply the model in England      idea grew and people contacted us with
    including a literature review and research   a desire to be part of the process. People
    into a limited number of case examples       also contacted us and wanted to meet and
    of current strategic partnerships in         discuss ideas with community led housing
    England                                      organisations and faith groups.
• Include stakeholder engagement with
    organisations representing housing
    associations (Community Housing Cymru
    (CHC), National Housing Federation
    (NHF), local authorities (WLGA and
    LGA), church denominations, and ‘not for
    profit’ housing delivery bodies

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REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
3. HOUSING NEED IN WALES
    3.1 HOUSING DEMAND                         paint an equally bleak picture. In 2018 a
                                                survey of 20 of the 22 Local Authorities
There is a demand for a significant increase    found that at least 60,569 households
in all types of new homes in Wales over         were on housing waiting lists. Pressure
the next five years. The most recent Welsh      has further increased on the Government
Government Report into Housing Need             and housing providers during the Covid-19
makes the following key points:-                pandemic to provide homes for those
• During the first five years (2019/20 to       previously homeless. This is creating a new
    2023/24), it is estimated that between      level of immediate need and inevitably
    6,200 and 8,300 additional housing units    placing further strain on local authority
    will be required annually, with a central   waiting lists.
    estimate of 7,400. These figures include      Julie James, the Minister for Housing
    an annual average of 1,100 additional       and Local Government, commenting on
    housing units to clear those in existing    the progress made in housing people
    unmet need over the first five years        without homes during the pandemic, has
• The additional annual housing need            said “we have housed over 850 people who
    estimate of 7,400 is split into 3,900       were sleeping rough and just over 2200
    additional market housing units (52% of     people in total in emergency temporary
    the additional housing need) and 3,500      accommodation who were in very volatile,
    additional affordable housing units (48%    unsuitable accommodation, sofa surfing
    of the additional housing need) over the    and people who didn’t really have anywhere
    next five years (2019/20 to 2023/24).       else to go but weren’t on the street.” This
    The Welsh Government’s latest central       is really positive but more permanent
estimate of housing need is for an              accommodation needs to be developed if
additional 114,000 homes across Wales           move-on models like Housing First are to
up to 2038. The central estimate of             make an impact.
housing need does not represent a formal          Further research is now underway
Government target for the number of new         to better understand housing need in
homes required to be built in Wales, but        Wales following recommendations by
does provide clear evidence of the level of     the Independent Review of Affordable
housing need to be addressed.                   Housing Supply.
    The Future Generations Report 2020
provides some worrying evidence of unmet
housing need in Wales, including:                 3.2 FUTURE GENERATIONS
•   Over 21,000 households faced or                    COMMISSIONER
    experienced homelessness in Wales in
    2018                                        The Future Generations Commissioner
• 2,139 households were in temporary            for Wales has identified that having a
    accommodation in Wales, of which 837        good quality home that meets their needs
    were families                               as a vital part of a person’s wellbeing.
    The housing waiting lists across Wales      Further, The Future Generations report

                                                SCOPING A STRATEGIC PARTNERSHIP               9
REPORT FOR FAITH IN AFFORDABLE HOUSING - SCOPING A STRATEGIC PARTNERSHIP
2020 makes a compelling case that poor-
quality housing is strongly associated
with inequality, poverty and limited life
chances. The Commissioner recognised the
importance of housing and how housing
related problems are affecting more people
than ever before. Ever increasing housing
need compared to supply is compounded
by the poor quality of the existing stock
in Wales – which is some of the oldest
housing stock in Europe. The report
outlines how 90% of this stock is predicted
to remain in use in 2050.
     The report argues that increasing the
supply of affordable, adequate, low carbon
homes within cohesive communities
must remain a policy priority in the long-
term. The report supports new innovative
solutions to bring empty buildings back
into use and to bring forward available land
for development.

  3.3 HOUSING ASPIRATIONS
       OF THE GOVERNMENT

The Minister for Housing and Local
                                                ▲ New houses built on the St Lukes Church
Government has ambitious plans for
                                                  in Porth.
housing in Wales and this is echoed in its
National Strategy Prosperity for All. It
identifies housing as one of the main five
priority areas which can make the greatest      to support the delivery and improvement
potential contribution to long-term             of social housing, bringing the total budget
prosperity and well-being. The objective        for social housing grants to £223m. The
of this strategy is for everyone to live in a   plan to build affordable housing has
home that meets their needs and supports        included a programme of innovative
a healthy, successful and prosperous life.      housing; setting new thresholds for offsite
Good quality homes are the bedrock of           manufacture and eco standards, rural and
communities and enable individuals and          cooperative housing.
families to flourish in all aspects of their      The Minister for Housing and Local
lives.                                          Government has committed to permanently
     In order to ensure the delivery of this    house those people without access to
national strategy, the Government has           accommodation that were supported
committed to delivering 20,000 affordable       through the Covid-19 pandemic and has
homes over the period 2016-21; with a more      also campaigned for access to housing
ambitious target expected for the next five     to be recognised as a Human Right and
years. The Government has provided an           has committed to working towards this in
additional £133m in the most recent budget      principle.

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COMMENT
Whatever source material or methodology is used to measure whether there is a future
demand for affordable housing in Wales it is unquestionable that there is a demand, which
will not be meet without an increase in supply.
  The Welsh Government has demonstrated a commitment to developing more homes
by providing additional capital resources. Welsh Government is also using a range of
different levers to increase the supply of affordable housing including; higher grant
rates than elsewhere in the UK and by targeting grants for innovation, co-ops and rural
schemes.
  Senior staff in the Welsh Government’s Housing Division have also participated in the
production of this report.

    The Minister for Housing and Local
      Government has ambitious plans
         for housing in Wales and this
   is echoed in their National Strategy
                      Prosperity for All.

                                                  SCOPING A STRATEGIC PARTNERSHIP           11
4. THE SUPPLY OF LAND FOR
    AFFORDABLE HOUSING IN WALES

 4.1 BACKGROUND                                                        4.2 LAND SUPPLY FOR
                                                                            AFFORDABLE HOUSING
The Independent Review of the Supply of
Affordable Housing included an extensive                             The development of affordable housing
review of the funding of affordable housing.                         in Wales has been following the English
The Welsh Government has responded                                   experience for a number of years with
to that review with changes to its grant                             the procurement of land from the open
and funding mechanism in an attempt to                               market becoming an ever bigger part of
increase the numbers of homes delivered                              delivering the new build social housing
through their programmes. This report does                           programme. The table below is from Welsh
not comment on the funding mechanisms                                Government statistics.
but concentrates on the supply of land                                 Historically, local authorities and other
available for affordable housing.                                    public bodies sometimes sell land direct
                                                                     to Welsh housing associations without
                                                                     competition. They do so to support the
                                                                     authorities strategic housing enabling role.
                                                                     On occasions, land has been provided free

 Source of Land Supply      2016/7                          2017/8                           2018/9

                            Total number   Expressed as a   Total number    Expressed as a   Total number   Expressed as a
                            of homes       % of the total   of homes        % of the total   of homes       % of the total
                                           programme                        programme                       programme

 Additional housing         932            37%              773             33%              604            23%
 delivered through the
 planning process

 Land made available from   689            27%              531             23%              650            25%
 public sources

 Rural exception sites      33             1%               49              2%               52             2%

 Land delivered through     892            35%              963             42%              1286           50%
 other sources

 Total new build housing    2,546          100%             2,316           100%             2,592          100%
 programme.

12   REPORT FOR FAITH IN AFFORDABLE HOUSING
▲ Architects Impressions of the housing proposed at Northop Flintshire.

for very expensive schemes like hostels                             acquisition now occurs almost entirely
or at sub market land values for social                             through the open market. Reviewing the
rent housing3, affordable rents and mixed                           Brownfield Register of Land4 in a number of
tenure.                                                             areas, the amount of public land available is
   Bringing public sector land forward for                          relatively low across England. For example
development has not been an easy process                            in Bristol it is only 14.5% of the total land
and frequently has a long lead in time. In                          on the register. Reflecting greater public
England, the One Public Estate programme                            land availability in the North of England,
was established in 2013 to regenerate and                           the figure for Leeds is 39.6%.
make better use of the public estate in                                Land acquired through the planning
England. Yet by 7 March 2018 only 303                               process still remains significant5,
homes had been built. Further housing                               accounting for over 23% of new social
developments were in the pipeline and                               housing delivered in 2018/19 in Wales and
other outcomes had been achieved. This                              49% in England. The National Housing
demonstrates how difficult it is to get the                         Federation in England believes that this
whole public sector to follow one objective                         source of new build development will
and release land for housing.                                       reduce further as result of the recent UK
   The declining availability of local                              Government announcement on deferral of
authority and public sector land to support                         the Section 106 commitments in England.
social housing was recognised by the                                   By 2018/9, almost half of the land used
Housing and Local Government Minister                               for building affordable housing in Wales
Julie James who made this statement                                 came from the following sources:
to the Senedd following the Affordable                              • Procurement through competitive
Housing Supply Review “the public sector                               bidding in the open market
needs to be more sophisticated in the way                           • A direct purchase between a housing
we use public land to support the widest                               association and a vendor, facilitated by a
range of objectives than simply generating                             land or estate agent. A site with planning
the highest capital receipt.”                                          or outline planning permission will of
   In England, consultees reported that                                course command a higher sale value and
in most new build development land                                     with it a higher agents fee

3. Land value discounts tend to be higher where social rent housing is to be developed than where affordable rent and
    mixed tenure housing is to be provided.
4. Brownfield land registers provide up-to-date information on sites that local authorities consider to be appropriate for
    residential development.
5. Land acquired through the planning process is also a competitive process between housing associations and
    occasionally a competition between housing associations and not for profit organisations.

                                                                    SCOPING A STRATEGIC PARTNERSHIP                           13
• Housing associations directly employing                             The other small but important
     their own land agents find land that                          contributor to the supply of land for
     they can then buy direct from the                             affordable housing is through rural
     owner. Larger housing associations will                       exception sites. As the name suggests,
     frequently employ a number of land                            these should be an exception to normal
     agents to ensure a forward supply of                          planning guidance. The majority of Local
     land for their development programme                          Development Plans6 in Wales include
• A house builder/developer bringing a                             a policy on rural exceptional sites. The
     proposed housing scheme direct to a                           number of properties delivered through this
     housing association with either outline                       route is relatively small, at no more than 50
     or full planning permission and then                          per year, as it requires legislation, specific
     seeking to dispose of the site linked to                      guidance, policy commitments in Local
     a contract for the developer to build out                     Development Plans and a considerable
     the homes                                                     amount of activity from both planners and
                                                                   Rural Enablers working for local authorities
     This is increasingly common form of                           and the Welsh Government. The need
     land procurement and ultimately new                           for this level of public expenditure to
     build development. Prime sites are                            achieve 50 additional properties clearly
     often developed direct for market sale                        demonstrates how hard it is to build
     and this model frequently operates                            housing and in particular build social
     counter cyclical to the market. When                          housing in rural areas.
     house sales in the private sector slow
     down developers then look to this
     model to build out potential sites.
     Conversely, as more private sector
     developers build out sites for the
     open market there are greater gains
     in affordable housing through the
     planning system.

          The majority of local development
          plans in Wales include a policy on
                      rural exceptional sites.

6. Local Development Plan - Since 2004 each local planning authority in Wales has been required to produce a Local
    Development Plan that sets out each local planning authority’s proposals for future development and use of land in their
    area.

14    REPORT FOR FAITH IN AFFORDABLE HOUSING
5. LAND OPPORTUNITIES
    5.1 BACKGROUND
Churches and faith groups own
approximately 4500 buildings in Wales
(churches and community buildings).
Many will be well used with thriving
congregations and active community
organisations. However, a number are being
considered for redevelopment for a variety
of reasons:
• Reduced congregations and the
    rationalisation of churches to operate
    over a wider area. Figures are difficult to
    quantify but it is estimated that between
                                                  ▲A
                                                    community hall in Merthyr Tydfil being
    10 and 20 churches a week have been
                                                    considered for affordable housing.
    closing in Wales
• Community Buildings may be under used
    or need significant repairs                   potential development opportunities. It
•   Churches and community buildings may          is also important to consider that land
    be energy inefficient and need to be          and buildings owned by the churches and
    replaced with new and easier to maintain      faith groups are frequently in areas where
    buildings                                     housing is most needed. In the context of
This direction of travel has been                 enabling rural housing, the buildings and
accelerated by the global COVID-19                church halls in these areas are all located
pandemic. The restrictions on worship,            inside the settlement boundaries and
weddings and funerals have all had an             therefore avoid the cost and complexity
effect on the income and viability of             of turning a green field site into new build
churches. Church services have moved              housing. Sites developed in urban areas
online and, like town centre offices, the         have also been part of the renaissance of
rationale for having an expensive to              towns and cities, transforming empty and
operate church building is diminishing.           occasionally derelict buildings into high
Community buildings and church halls have         quality housing. Local Planning Authorities
also suffered as result of the pandemic.          recognised the importance of community
Clubs and activities that have used the           consultation in bringing forward
venues and paid rent, such as toddler and         rural exception sites. As community
OAP groups and yoga and keep fit classes          organisations, churches can be a positive
ceased to do so for a substantial part of         force in the planning process. If their
this year. Many have not reopened and             members support the proposed change of
some may never do so.                             use it helps reduce the friction of that can
    Even the disposal of 10% of the land          occur when building social housing in some
holdings of churches could free up 450            communities.

                                                  SCOPING A STRATEGIC PARTNERSHIP               15
5.2 IS THE ENABLED LAND                                        requirements an independent valuer must
       VALUE FOR MONEY?                                           support the valuation. However, this does
                                                                  not have to be via a tender or a full market
When a faith group follow their social                            offer. This allows a consideration of best
conscience and sell land based on a                               value.
valuation rather than open market tender
it has a financial benefit to both the                               In 2017/18, Welsh housing associations
Government and the housing association.                              spent £56.8m on land acquisitions.
Excluding the fact that without this support                         With Welsh Government social
the housing might not be built, and even                             housing grants averaging 58% of
with the Welsh Government’s move scheme                              scheme costs this means that the
specific a viability grant rate7, the viability                      Welsh Government contributed
of the scheme is always improved by the                              around £32m towards the cost of land
sub market valuation and sale of land.                               acquisition.
     To comply with Charity Commission

  Benefits to the Government of land sales                     Benefits to Housing Associations of land
  based on a valuation rather than open                        sales based on valuations rather than
  market disposal                                              open market disposal

  A direct saving of social housing grant as                   A lower cost scheme means that housing
  a result of the lower land price in the total                associations are using less of their capital
  scheme cost                                                  to support a scheme. As a consequence,
                                                               less revenue is required to service debt

  Unused grant can be used to provide                          Lower volumes of borrowing mean lower
  additional social housing                                    interest cover

  Savings on future Housing Benefit on                         Negotiated sales reduce risk and the cost
  the lower social rent compared to higher                     of tendering that includes all abortive
  market rent                                                  preliminary works

7. A
    viability grant rate is one designed to meet the gap funding between a schemes cost and the net present value of
   future rent income.

16    REPORT FOR FAITH IN AFFORDABLE HOUSING
6. ENABLING NEW SITES
  6.1 BACKGROUND                                  PHASE TWO
                                                  AN INITIAL ASSESSMENT
A number of churches and faith groups             • HJC will undertake an initial assessment
in Wales have positive policies where the           of the opportunity. This will include a site
support for providing affordable housing            visit to assess physical condition of the
is seen as a ‘Christian duty’. At a national        property and a Land Registry search to
level, most denominations now have strong           ascertain the nature of any covenants,
and supportive principles, but as one               restrictions or reversion clauses
church asset manager put it “people might         • HJC will give examples of other
be Christians but they do not always show           successful schemes and appraise
Christian values when it comes to wanting           the group of probable Charity
social housing in the neighbourhood on              Commissioners views of the proposals
land they own”.                                   • A short technical assessment in terms
  HJC currently operate in this space               of planning policy context, ecology and
between national Governments                        flood risk
and national faith bodies and local               • Finally, a meeting will be held with the
denominations making a positive choice              church to discuss whether it is to be a
to dispose of assets to support affordable          simple disposal or whether the church
housing. The text below provides a                  requires a retained interest in the
summary of the five phases of this work.            completed development

                                                  COMMENT
PHASE ONE                                         HJC could undertake better financial
IDENTIFYING THE                                   viability assessments if they created an
OPPORTUNITIES                                     appraisal model which had access to Welsh
• An approach is made by a church                 Government data from social housing grant
  denomination or their appointed agent/          submissions.
  advisor as to a potential opportunity
• HJC itself identifies a potential opportunity
  for discussion with a denomination              PHASE THREE
                                                  LOCAL AUTHORITY LIAISON
COMMENT                                           • HJC works with the local authority to
Site identification is an area where HJC            identify housing need and any specialist
needs more resources, including field staff         requirements that the authority may
and publicity, are needed to ensure a faith         have for a site
group thinking about asset management             • HJC review funding opportunities
consider a sale for affordable housing.             from Welsh Government with the local
  Creating closer links at this stage with          authority
the Welsh Government Enabling Team
could produce additional benefits.

                                                  SCOPING A STRATEGIC PARTNERSHIP               17
COMMENT                                            6.2 THE ADDED VALUE
In rural areas, the phase 3 work of liaising            OF HOUSING JUSTICE
with local authority is a role that could be            CYMRU
undertaken by the Welsh Government’s
Rural Enabling Team.
                                                  The process of building affordable housing
                                                  on faith owned land is complex. The focus
                                                  groups identified several reasons why the
PHASE FOUR                                        role of HJC has been uniquely important in
IDENTIFICATION OF A                               enabling social housing:
DEVELOPMENT PARTNER                               • Honest broker – HJC is seen as honest
• HJC will ask the local authority to               broker between the housing associations
     identify which housing association to          and the faith group
     work with or whether the authority           • Faith to faith relationship – It has been
     wishes to build on the site themselves         easier for HJC to present a faith based
• If there is no local authority view on a          rationale that the provision of land for
     specific developing housing association        social housing is a Christian duty than a
     then HJC identifies a suitable developing      non-faith based organisation could
     housing association to develop the           • Continuous commitment to affordable
     opportunity, following a standard              housing – HJC has been unwavering in
     protocol that it has developed                 its commitment to social housing and
• HJC propose the scheme to the housing             have been able to steer faith groups
     association and manage relations               towards this outcome and away from
     between the faith group and the housing        straight commercial disposal
     association                                  • Success of other schemes – HJC has
                                                    a track record of successful schemes
COMMENT                                             across Wales providing proof that well
It is recommended to replace this stage             managed and well designed social
of the process with partners from the               rented housing can be provided
framework being used to appraise the
opportunity. If the new operation model
proposed in this report is adopted the
organisation chosen to develop the scheme
could carry out the appraisal.

PHASE FIVE
CONTINUED LIAISON WITH
FAITH GROUP
• HJC continues to work with the faith
     group until the scheme is completed

COMMENT
In rural areas this liaison role could be taken
on by the Welsh Government Enabling
Team keeping in contact with the group
through the planning and development
phase.

18    REPORT FOR FAITH IN AFFORDABLE HOUSING
COMMENT
Affordable housing sites on land owned by faith groups will not bridge the gap between
declining public sector provision and the need for housing in Wales. They can however,
make an important contribution to the affordable housing supply by enabling sites in
critical rural locations and in towns and city centres with limited land supply.
  Developing housing through the Faith in Affordable Housing Programme is good value
for money for the Welsh Government as it brings forward housing sites outside of a
competitive market and frequently at sub market values. One senior housing association
figure described the opportunity to buy land pre-market as “very valuable” and the
opportunity to buy discounted land as “golden”.
  It is very difficult to perceive the role played by HJC in enabling affordable housing land
supply being undertaken by a statutory body or a beneficiary of the land sales.

RECOMMENDATIONS
• Work is undertaken to identify the scale and potential of available land owned by faith
  groups in Wales
• A closer working relationship is developed between the Welsh Government’s Enabling
  Programme and the work of Housing Justice Cymru
• Expand the number of properties delivered through the Faith in Affordable Housing
  Programme will require investment via marketing to faith groups and direct contact
  outreach work

                                                   SCOPING A STRATEGIC PARTNERSHIP              19
7. A STRATEGIC HOUSING PARTNERSHIP
    FOR THE FAITH IN AFFORDABLE
    HOUSING PROGRAMME
 7.1 BACKGROUND                                         standards and/or community clauses in the
      ON A STRATEGIC                                     contract.
      PARTNERSHIP                                           Conversely stretching the affordable
                                                         housing target upwards has the potential
The intention of this report was to explore              to reduce either the capital receipt to the
the potential for a strategic partnership                vendor or reduce the added social value
between housing associations and                         clauses included in the disposal. Pushing
HJC. And to assess whether a strategic                   for greater levels of social value through
partnership could deliver greater social                 management standards and conditions,
benefits. Developing affordable housing is               through constraints on rent levels or
a three way balance. If the vendor seeks to              social clauses in contracts can reduce
increase the capital receipt from the sale               either the capital receipt to the vendor or
this means either reducing the number of                 the potential number of affordable units
affordable homes or lowering the social                  developed.
value requirements on management, design

                                             Capping
                                             rent levels,
                                             defining higher
                                             build standards
                                             or including other
                                             social value
                                             conditions

                                                01

                   02                                                 03
                   Number of                                          Capital receipt
                   affordable homes                                   from the land
                   developed                                          sale

20 REPORT FOR FAITH IN AFFORDABLE HOUSING
There is no opportunity for
                        economies of scale and
                   model locks in additional cost.

  The approach of HJC and the FiAH              • There is limited potential to smooth
programme to date has been successful               out the cost of higher risk and more
with 357 homes developed or in the                  expensive sites where there are
future pipeline. However the potential for          infrastructure, service and other
additional sites and greater social value was       constraints with other easier to develop
one of the drivers for the commissioning            schemes
of this scoping report to review and help       • There is limited opportunity to
create a strategic partnership that allowed         develop economies of scale within this
this project to work at a larger scale.             programme. Welsh housing associations
  There are a number of inefficiencies in           have of course the potential to improve
the current system as the programme is              the economies of scale by blending
mostly based on small scale sites and HJC           site opportunities with other parts of
works with a large number of associations           their development programme. But HJC
and local authorities across Wales. The             allocates opportunities based on the
model offers no opportunity for scaling up          advice of the relevant local authority,
the programme by identifying new sites as           rather than other development activity
there is no income being generated by HJC.          of a potential partner. There is also no
  There is no opportunity for economies             data available on whether economies of
of scale and the model locks in additional          scale materialised (and who benefited
costs through relearning, inefficiency and          from them) through blending this
administration.                                     programme with other development
  In talking to stakeholders this we found          activity
weaknesses in the current programme:            • There is limited potential for shared
• Developing partners had no certainty              learning and the potential for the
  of a future new build programme.                  creation of standard or model
  No organisations involved could                   documents is limited
  therefore predict their treasury              •   Administratively this multiple developer
  management funding needs from sites               model is cumbersome as each scheme
  enabled through this programme. It                requires new relationships, fresh
  was considered an addition to the                 dialogue and the management of
  programme and was not factored into               expectation of both vendor and the
  borrowing                                         acquiring developer
                                                • HJC gains no income in the current
  Most organisations that are building              model meaning there are no resources to
  affordable housing schemes know                   identify new opportunities and expand
  that the retention of skilled people              the programme. This further reduces
  with the right skills presents a high             the economies of scale that could be
  risk due to a shortage of the right               obtained by a bigger programme
  people. This risk is easier to mitigate       • A more experienced group of developers
  with a pipeline of schemes to develop.            can help mitigate the risk of a challenge
                                                    from the Charity Commissioners

                                                SCOPING A STRATEGIC PARTNERSHIP                21
• Working with experienced partners             company in which some, but not all of
  can help dampen the expectations of           the GMHP, have invested to deliver more
  landowners on land value and help to          complex development opportunities
  ensure that the faith aspirations remain      that might be too big for individual
  in the commercial mix                         organisations. The scale of the GMHP with
                                                28 members and a combined development
                                                programme of over 8,000 homes a year is
  7.2 T
       HE GREATER                              similar in scale to the whole Welsh housing
      MANCHESTER                                association sector. Parallels can also be
      HOUSING                                   drawn between the political relationship
      PARTNERSHIPS                              between the GMHP and elected regional
                                                city Mayors and the existing relationship
One of the most important and widely            between Welsh associations and the
acclaimed strategic housing partnerships        devolved housing administration in Wales.
in UK Housing is the Greater Manchester           The GMHP development company model
Housing Partnership (GMHP). Most                did have potential to resolve some of the
strategic partnerships are project or           issues in the FiAH programme operating
location specific. However, the GMHP            model, but through further discussions with
is of a similar scale to the whole Welsh        stakeholders in Wales it was rejected for a
housing association sector. It was therefore    number of reasons including:
important to consider whether this model        • Any development company would
could work in Wales and remove some of            require extensive confidence building
the inefficiencies in the current operational     between partners (this was achieved
model of the FiAH programme. This is              through the wider GMHP before the joint
not intended as a full review of the merits       development company was established)
or the successes of the GMHP but just           • Being seen as too complex a model for
whether it could be adapted to work in            the potential benefits
Wales for HJC.                                  • Might, depending on the nature of
  In considering the GMHP it needs to             the strategic partnership and the loan
be recognised that there are a number             agreements, require both Funder and
of different levels, connections and              Regulatory approval both of which
relationships within this strategic housing       would be time consuming, require legal
partnership. The wider GMHP is a coalition        advice and funder approval – adding
of like-minded housing organisations,             cost and risk
public authorities and elected political
leaders in Greater Manchester which have
agreed common values and goals through            7.3 REJECTING A
a Memorandum of Understanding. This                    STRATEGIC HOUSING
common commitment has supported and                    PARTNERSHIP
nurtured positive relations and mutual
understanding, particularly around              In housing, the term ‘strategic partnership’
regeneration and training. The members          carries a lot of baggage as it is a ‘catch-all’
pay an annual fee and with this revenue         term for a wide variety of relationships. Its
employed workers to research for and            use stretches from a joint venture company
service the partnership. Different partner      sharing resources and equity with a binding
Chief Executives lead on different areas of     legal agreement through to commercial
the partnership depending on their skills       contracts between organisations, pre-merger
and the goals of their own organisation.        strategic alliances, to relationships between
The building of positive relationships has      local authorities and housing associations
helped to create a joint development            and to informal alliances based on common

22 REPORT FOR FAITH IN AFFORDABLE HOUSING
values. It became clear from discussions        b) The valuation of land and social value will
that the vagueness of the term ‘strategic         be captured through an agreed formula
partnership’ would therefore cause potential    c) Membership will be limited to a small
concerns for many stakeholders in Wales. In       number of organisations
addition there were other concerns about        d) Membership will be time limited with an
the efficacy of the development company           option to renew
model:                                          e) There will be selection criteria for
•   It would need to evolve organically           partners developing any housing – that
    with self-selecting partners developing       includes local management standards
    mutual values rather than being a             (including Welsh language), rent levels,
    construct of HJW                              tenancy types, design and eco standards
•   It has the potential to create inter          and the generation of local employment
    dependencies that would need careful          opportunities
    management and might require                f) Membership will be obtained through an
    expensive legal advice to manage              open selection process where potential
•   It carries an expectation of a high level     partner organisations demonstrate their
    of joint working that Welsh housing           ability to meet or exceed the criteria set
    associations are not yet ready for            out above
                                                g) The strategic partnership will involve
                                                  members sharing the cost of marketing,
    7.4 FINDING THE RIGHT                        promotion, land assembly and the
         RELATIONSHIP                             development of model documents
                                                  In rejecting the model of strategic
The opening assumption in this report           partnerships consultees did recognise
was that once a strategic partnership was       the need for change in the current FiAH
in place it would operate in the following      operational model and felt that a smaller
manner:                                         number of development partners should be
a) All site opportunities developed by HJC      the strategic goal.
    will be exclusively developed by the
    partnership members

                                                SCOPING A STRATEGIC PARTNERSHIP 23
SUMMARY OF THE BENEFITS OF REDUCING THE NUMBER OF POTENTIAL ORGANISATIONS

  Constraints of the                Consequences of these                       Potential of a more focused
  current operating                 constraints                                 or strategic approach
  model

  Each scheme has a                 Each development requires                   Working with a much
  different partners                the building of new                         smaller number partners will
                                    relationships between Welsh                 bring greater knowledge
                                    housing associations, faith                 and understanding of the
                                    groups and HJ. Understanding                process. The participating
                                    of the expectations of the                  organisations can build
                                    other partners has to be                    and retain expertise and
                                    relearnt in each development.               thus get the best out of the
                                       A experienced FiAH parter                partnership.
                                    would bring engender more                      The success of previous
                                    realism amongst land owners                 schemes engenders
                                    on land values.                             confidence in the programme
                                       Failure to appreciate                    and allows a more mature
                                    the different in Charity                    relationship between vendor
                                    Commission guidance on                      and developer.
                                    land disposal - in England the                 A smaller number of
                                    advice is to seek the highest               partners will have the
                                    price but in wales the advice               opportunity to develop model
                                    is to seek ‘best value’.                    agreements with HJW, thus
                                       Limited opportunity to                   reducing the professional fees
                                    reduce costs by developing                  in the system8.
                                    model documents.

   COMMENT
   Whilst the Greater Manchester Housing Partnership has delivered some tangible benefits
   to members, it did not offer a model which could help HJC reduce the number of partners
   it is working with.

   RECOMMENDATIONS
   Having consulted housing organisations in Wales and reviewed the benefits and potential
   risks, HJC has rejected the idea of creating a strategic partnership and asked the report
   authors to create an alternative model.
      The view of housing associations consulted for this report, and the Welsh Government
   is a more focused group of developing partners was needed if the FiAH model was to be
   more widely implemented.

8. It is recognised that larger developing RSLs have standard contracts and agreements – but these will not be bespoke to
faith based developments working under the constraints of the Charity Commissioners.

24 REPORT FOR FAITH IN AFFORDABLE HOUSING
8. A NEW OPERATING MODEL
  8.1 A
       NEW OPERATING                              8.2 PROCUREMENT
      MODEL                                             FRAMEWORKS IN
                                                        HOUSING
Although the stakeholders rejected a
strategic partnership model they did             All developing social landlords in Wales
support the hypothesis that greater              will have used a framework as part of their
efficiencies could be achieved through           procurement process. Frameworks are
working with a smaller number of partners.       very common in procuring repairs and
Stakeholders also valued some of the             maintenance and increasingly common in
strategic partnership benefits set out in        the procurement of services. Procurement
Section 7.4 namely:                              through a framework is a form of tendering
a) All opportunities created by HJC will be      where different organisations submit a
  exclusively developed by partnership           tender proposal setting out their skills,
  members                                        competence, experience, explaining how they
b) The valuation of land and social value will   will undertake the work, the added value they
  be captured through an agreed formula          will bring to the process and their proposed
c) Partnership membership will be limited        costs. The awarding body then scores and
  to a small number of organisations             ranks these proposals against a set of pre
d) Membership will be time limited with an       agreed and defined criteria. Those judged to
  option to renew                                offer the right mix of cost and quality (the
e) There will be selection criteria for          most economically advantageous tender)
  partners that includes local management        become the framework members.
  standards (including Welsh language),            When works or services are then procured
  rent levels, tenancy types, design and         the contracting body awards work contracts
  eco standards and the generation of            to the framework members. Depending on
  local employment opportunities                 the nature of the framework this could be a
f) Membership will be obtained through an        direct award or even a mini tender between
  open selection process where potential         organisations on the framework.
  partner organisations demonstrate their
  ability to meet or exceed the criteria set
  out above                                        8.3 IDENTIFYING
g) The model will involve members                       FRAMEWORK
  sharing the cost of market, future land               PARTNERS
  assembly and the development of model
  documents                                      The recommendation is to follow the
  After some discussion, the stakeholders        methodology of a framework tender to
identified a competitive but open process        find the right organisations to develop new
where organisations submitted applications       affordable social housing with HJC. After
to join a framework as a development             consultation with Emily Powell and Caroline
partner. The process was similar in nature       O’Flaherty, partners at Hugh James, the
to a procurement framework.                      following framework model is proposed.

                                                 SCOPING A STRATEGIC PARTNERSHIP 25
▲ St Matthews Church, Newport. Before the work started, after work was finished, and a visit
  from the Archbishop of Wales.

  We believe the framework model can be delivered, that it will meet the housing sector’s
  expectations of transparency and will be robust if challenged.
     The framework will cover the selection of housing associations or local authorities for
  the Faith in Affordable Housing programme. The framework will not cover the sale of
  land, any contracts for work or any linked construction contracts. Nor would it be used to
  determine the ownership of any properties developed.
     The selection process proposed is more of a ‘beauty contest’ rather than a formal
  procurement process. However, there will be a need for additional detailed legal advice
  to ensure the process remains complaint with procurement legislation during its
  implementation.

  In recommending a framework one of                Housing framework proposed here will
the options considered and rejected was             require a competition between willing
whether the HJC and faith groups could get          housing organisations using the two part
better value out of a open market tender            evaluation process.
process. One in which every opportunity
identified was marketed to every WHA and            PART ONE – Assess whether the
LA and then each application and bid is             organisation has the skills, competence
assessed. Whilst this would guarantee that          and experience to the deliver the probable
each scheme was the best value available            programme based on the information
at that point, all of the benefits identified of    provided and other published data.
working with a narrower group of partners
would be lost.                                      PART TWO – Assess what additional
  Establishing the Faith in Affordable              benefits the organisation bring to the

26 REPORT FOR FAITH IN AFFORDABLE HOUSING
programme. Here, housing organisations                It is recommended that extracting the
will be asked to offer a number of                  information set out in part 1 and 2 above
additional benefits, ranging from                   will involve the nine stages set out in the
regeneration and training, commitments on           table below and it is estimated that this
rent, on housing management, on Housing             process will take about six months to
First or a range of other imaginative offers        implement.
that will improve the outcomes from the
programme.

  Stages in       Events and activities
  selecting
  framework
  partners

  1               Grant application to Funding Organisation – the project needs pump
                  priming to start the process and obtain the detailed legal advice

  2               Define the framework terms – working with a group of partners from the
                  faith community

  3               Develop the procurement documents – the invitation to tender documents,
                  the evaluation methodology, any geography and lot divisions and the
                  terms of engagement

  4               Carry out market consultation and identify potential framework members

  5               Advertise the framework and invite submissions – from those organisations
                  identified in step 4

  6               Establish the selection panel – which would include faith organisations

  7               Evaluate and rank the submissions – this might include regional or lot
                  divisions

  8               Appoint prospective partners to the framework partnership

  9               Commence partnership working

  Most stakeholders felt that any process           the design and evaluation of any criteria.
to limit the number of organisations in each        The staged process above meets these
framework needed to be a transparent and            objectives.
that faith groups needed to be part of both

                                                    SCOPING A STRATEGIC PARTNERSHIP 27
8.4 S
       CALE AND SIZE OF                                 housing sector in England; however this is
      THE FRAMEWORK                                      still a growing sector in Wales and might be
                                                         seen as a potential partner for management
The FiAH programme currently works                       rather than as a full framework member at
exclusively with the regulated housing                   this stage. One interviewee felt that many
sector in Wales and it is recommended that               housing associations in England had lost
this continues. Faith stakeholders identified            their community focus in a drive towards
three factors in choosing potential partners             commercialism and one of the responses to
to build social housing with:                            this has been the creation and subsequent
1. That any properties developed remain in               growth of genuine community led housing
  social rent in perpetuity. This was viewed as          in England. Stakeholders in Wales did not
  an increasingly important factor following             identify with this maxim and a level of trust
  policy changes in England. Some housing                was retained in the regulated housing sector.
  policies such as the Right to Buy (including              There are currently 22 local authorities
  voluntary) and the proposed Right to                   and 70 housing associations (including
  Shared Ownership have undermined                       community mutual and mutuals) in Wales.
  confidence in England that the housing                 Of these 92 organisations not all are actively
  will remain in perpetuity and this has the             developing new build homes. It is estimated
  potential to reduce the willingness to                 that the number undertaking development
  dispose of land for affordable housing.                of new build housing is between 30 and 40.
2. That the organisations with whom they do                 The total number of homes enabled
  business with will retain the provision of             through the FiAH programme to date is
  affordable housing as their core purpose.              357 and Section 5 of the report identifies
3. That they are regulated by the Welsh                  that there is future potential for a bigger
  Government, operate to published                       programme. It is recommended that the
  standards of probity and meet defined                  number of developing partners whom FiAH
  housing management and build quality                   work with is aligned to match the scale of
  standards.                                             the potential programme. The final structure
  There has been a growth in the number                  of the framework should provide also
of ‘for profit’ regulated providers in England           provide flexibility for the future creation of
in recent years. However, these new entrants             sub-regional frameworks.
have had little traction in Wales and it is                 The Welsh Government is currently
recommended to remain with the regulated                 considering the zoning of Social Housing
housing sector of Welsh housing associations             Grant in Wales. Community Housing
and local authorities in the first round of              Cymru, the trade body for Welsh housing
the faith in affordable housing framework.               associations, has reported that the latest
In Section Two of this report we make the                Government thinking is that there will be
case made for involving the community led                three housing development zones for Wales.

  Zone                                         Welsh Local Authorities

  North Wales                                  Ynys Mon, Gwynedd, Conway, Denbighshire,
                                               Flintshire and Wrexham

  Mid and South West Wales                     Powys, Ceredigion, Pembrokeshire,
                                               Carmarthenshire, Swansea and Neath Port Talbot

  South East Wales                             Bridgend, Vale of Glamorgan, Rhondda Cynon Taf,
                                               Merthyr Tydfil, Cardiff, Caerphilly, Newport, Blaenau
                                               Gwent, Torfaen and Monmouthshire

28 REPORT FOR FAITH IN AFFORDABLE HOUSING
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