An email has been sent to CLG requesting clarification of the figures used to justify the government's proposal to allow renegotiation of Section 106 agreements concluded before April 2010. As our news story noted, the figures supplied in the consultation document were not accompanied by any detail as to the methodology used.
The email read as follows:
Dear Sir or Madam
I am writing in connection with the consultation document entitled “Renegotiation of Section 106 Planning Obligations”, the proposals in which are justified on the basis of there being many stalled sites where renegotiation of S106 agreements is required.
The relevant text in the document occurs in paragraph 2 on page 3:
“There are currently around 1400 housing schemes of over 10 housing units with planning permission that are stalled. 62% of stalled units predate April 2010.” This is the only information supplied to support the need for the proposed change to the legislation. The footnote states the source of the information as “Glenigan, as at June 2012”.
Given the centrality of this figure to the policy proposals, it would seem appropriate for fuller details to be made available – in particular the methodology used to arrive at the figure in question including the definition of a “stalled site” and how it was established that the obstacle to progress was the failure of the local authority to voluntarily renegotiate the Section 106 agreement. Could I thierefore ask you please to supply whatever further details exist to support the figures quoted, for example any full report from which the figures are drawn and, in any case, the methodology used.
I have written separately to Glenigan but given the fact that this is a government consultation and would be expected to comply with the current guidelines for consultation* it seems reasonable to approach you directly for the relevant information.
I look forward to hearing from you
* I refer particularly to the following statements in the Cabinet Office Consultation Principles :
“ Increasing the level of transparency improves the quality of policy making by bringing to bear expertise and alternative perspectives, and identifying unintended effects and practical problems.”
“Every effort should be made to make available the Government’s evidence base at an early stage to enable contestability and challenge”.
“Information should be disseminated and presented in a way likely to be accessible and useful to the stakeholders with a substantial interest in the subject matter.”
“Information provided to stakeholders should be easy to comprehend – it should … clarify the key issues, particularly where the consultation deals with complex subject matter”.
“Sufficient information should be made available to stakeholders to enable them to make informed comments.”
David Gibbens, Network Co-ordinator, Housing Enabling Network