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APPENDIX 12 – Tunbridge Wells Borough Council Older Persons Housing Strategy

Background

At the time of the 2001 Census there were 14,484 older people aged 65-84 years and 2,424older people aged 85 years or over living in the Tunbridge Wells Borough. Older peopleaged 65 years or over represented 16.3% of the Borough’s total population in 2001.

The 65+ age group is projected to increase significantly between 2006 and 2016. By 2016the over 65’s will represent 20% of the total population of the Borough, with much of theincrease the result of people living longer. Whilst most people over 65 continue to live ingood health, and the years of good health expectancy increase, there is a correlationbetween ageing and frailty, which places demand on housing support and related services.The projected increase in the 65+ age group has potential to put Home ImprovementAgencies under increasing demand that could not be met under current funding streams.

About one in six households in the Borough contain someone with a disability that requiressupport. The likelihood to require support increases with age with 64% of those needingsupport being over 60 years of age and 35% over 75 (Source: 2005 Housing Needs Survey).

Research undertaken to inform the Kent Supporting People Five-Year Strategy 2005-2010identified:

• a need for 40 extra-care sheltered housing units for frail older people.• the need to ensure that housing is suitable to meet older people’s expectations,

minimum standards and it is located close to facilities.• a need to re-focus existing sheltered accommodation and address the aspirations of the

majority of older people wanting to stay in their own homes for as long as feasiblypossible

Building on success – achievements to date

During the period of our Housing Strategy 2001-06, we have:

• Provided 236 Disabled Facilities Grants (DFGs) to assist disabled people – includingolder disabled people – with access and care facilities in and around their homes, furtherincreasing their independence.

• Provided 251 Home Repair Assistance/Home Improvement Grants to assist thosehouseholds – including older people – receiving an income-related benefit with repairs,heating and energy efficiency measures in their home.

• Continued financial support of the Council’s Home Improvement Agency, in touch(formerly Moat Care and Repair), which provides key services to vulnerable people –including older people – in the community.

• Assisted in the development of the Falls Reduction Strategy published in June 2004, amulti-agency Strategy which aims “to reduce the number of falls, which result in seriousinjury and ensure effective treatment and rehabilitation for those who have fallen”.

Where we need to improve

• Some sheltered housing for older people available in the Borough may not be suitable tomeet the needs of current and future residents’ aspirations.

• There is a lack of extra-care sheltered housing for frail older people.• The number of Registered Social Landlord (RSL) sheltered housing units becoming

available for reletting each year (average of 55 sheltered units per annum between 2002-

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2005) is less than the number of older households requiring affordable housingregistered on the Joint Housing Register (at April 2006 there were 238 households aged60 or over registered on the Housing Register, of whom 92 require sheltered housing).

What we plan to do

• Identify older people’s needs and preferences regarding sheltered and extra-carehousing by undertaking market research into older people’s housing needs andpreferences and reviewing existing Registered Social Landlord (RSL) sheltered housingstock to ensure it meets current standards and future preferences.

• Consider increasing funding for disabled adaptations, home repairs/improvements andaffordable warmth measures through a wider range of funding options to meet futuredemands on services.

• Improve links with Kent County Council’s Occupational Therapy (OT) Bureau in order toreduce waiting times for client OT assessments.

• Increase joint working with the Health Primary Care Trust, OTs, the Kent SupportingPeople Team and Health services to meet community care needs through referral toappropriate services.

• Reduce domestic hazards to the vulnerable by actively upgrading safety and securitymeasures in their homes (via in touch services and Council Home Improvement Grants).

• Seek to increase the provision of dedicated housing for older people, including extra-care sheltered housing (via a joint Private Finance Initiative – PFI – bid with other Kentlocal authorities under Housing PFI Round 5), to enable them to ‘downsize’ and live inthe community, close to local services.

• Continue to promote and provide older and disabled people with adaptations in andaround their homes, thereby increasing independence.

• Further develop the role of Housing Services within the Falls Prevention MonitoringGroup

• Seek to promote Lifetime Homes across all housing developments through application ofthe Kent and Medway Structure Plan Policy HP7 and Draft South East Plan Policies CC4and CC11, pending Planning Policy/Guidance under the Local Development Framework(LDF) process.

• Introduce an equity release loan scheme endorsed by the Council to assist olderhomeowners in funding repairs to their property.

Objectives and SMART actions to deliver the plans listed above are summarised in the mainHousing Strategy Action Plan shown at Appendix 1.

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APPENDIX 13 – Tunbridge Wells Borough Council Young Persons Housing Strategy

Background

At the time of the 2001 Census there were 9,762 young people aged 16-24 years living inthe Tunbridge Wells Borough (2,806 16-17 year olds and 6,956 18-24 year olds) of whom52% were male and 48% were female. Young people aged 16-24 years represented 9.4% ofthe Borough’s total population in 2001.

The population in the 16-24 age group is predicted to increase by 1,200 (12%) by 2011.

Building on success – achievements to date

During the period of our Housing Strategy 2001-06, we have:

• Established the Joint Assessment Referral Scheme (JARS) in December 2003 todetermine options and support packages for people – including young people – movingin and out of supported housing in the Borough. This brings together a wide range ofstakeholders, including staff from RSLs, supported housing providers, the YouthOffending Team (YOT) and Social Services care managers. Panel meetings for thescheme are well-attended and the approach is highly valued by partners. To date 156clients have been referred to the Panel and 57 clients have been rehoused in supportedaccommodation.

• Maximised use of family mediation services through Government Homelessness Grantfunding to achieve positive outcomes in keeping young people at home for a period oftime.

Young Persons’ Housing Needs Review 2005

In 2005 the Council appointed a consultant to undertake market research to:

• examine the suitability of provision of housing services for vulnerable young people up tothe age of 25 years in the Borough;

• identify gaps in provision; and• recommend future activities to meet their needs.

The research found that the Council housed a total of 421 people from the Tunbridge WellsJoint Housing Register in 2004/05, of whom 39 were under 25. In April 2005 there were 140single applicants under 25 years of age registered on the Housing Register, including 20under 18 years of age, and a further 105 applicants with partners under 25 years of age.

Although each agency involved with providing housing or housing-related services to youngpeople in the Borough keeps its own statistics, it is difficult to compare these, as there iscurrently no standardisation. There is also a danger of double-counting as it is likely thatyoung people with housing needs will visit several agencies. However, with this proviso, theresearch provided the following indicators of the level of housing need amongst youngpeople:

• 30% of Bridge Trust referrals are young people aged 16-24. Bridge Trust had a total of108 male and 38 female young people aged 16-24 referred by agencies in West Kent in2004/05. There is no further breakdown to local authority level apart from seven werereferred by Tunbridge Wells Borough Council, and 11 by Tunbridge Wells CitizensAdvice Bureau (CAB).

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• In 2004/05 the specialist housing caseworker at Tunbridge Wells CAB, who providesadvice funded by the Legal Services Commission, advised 16 young people, 15% of thecaseworker’s total workload.

• Since Colebrook Road Hostel (managed by Moat Housing Group) opened in July 2002,they have had 162 residents between the ages of 16 and 20 and 112 between 21 and 25(out of a total of 691). As 49% of the total number of residents have had a localconnection to Tunbridge Wells Borough, it could be assumed that over 100 of thoseaged between 16 and 25 were from Tunbridge Wells Borough.

• Crisis Recovery dealt with approximately 15 homeless people aged between 18 and 25in the year to April 2005.

Existing accommodation:

Provider Accommodation Length of StaySupported AccommodationWest Kent YMCA 24 self-contained flatlets

24 hour cover for 16--30 year oldsConnexions, CAB – life skills, counsellors, CVpreparation, budgeting advice

Up to 2 years

Christian Alliance HA 17 one-bedroom units for single homelesswomen aged 16-30 years, including 4 unitssuitable for mothers and babies up to 3 years.24 hour staff coverResidents allocated a link worker

Up to 2 years

The Bridge Trust Shared supported housing across 22 units in4 houses18-60 year olds (average age 30), few under25Support is provided by support workers

Not known

Moat Housing Association Hostel for non-priority homeless, mainly over18,s. 16/17 year olds accepted occasionally(if evicted and found intentionally homeless)Assistance in finding move-on housing –normally TMCA, Trinity Foyer, supportedhousing, Camelia Botnar Foundation(Cowfold). Moat provide floating support,Colebrook Road staff provide ad hoc support.

Up to 13 weeks

Temporary accommodation (used by Tunbridge Wells BC)Bed and Breakfast 2003/04 – 17 x 16/17 year olds placed in

B&B2004/05 – 14 x 16/17 year olds placed inB&B

N/A

One Hostel controlled byTunbridge Wells BC

10 one bedroom flats for homelessfamilies/single people including 16.17 yearolds

N/A

Existing advice/support services:

Provider Advice/Support ProvidedBridge Trust homelessadvice centre, Tonbridge

20 hours per week (4 days)

Shelter housing advicecentre, Ashford

County-wide advice line14.5 hours per week (5 days)9 hours per week for personal callers at Ashford

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Tunbridge Wells CAB 35 hours per week – Tunbridge Wells18 hours per week – Cranbrook20 hours per week – Paddock WoodGeneral advice, specialist housing advice for anyone receivingLegal AidOffer a Youth Advice project and holds outreach sessions atConnexions, TonbridgeProvides phone, text and e-mail advice

Tunbridge Wells BCHousing Needs Team

3xFTE Housing AdvisorsAppointments only and open surgeries held daily at Town Hall,Royal Tunbridge Wells, weekly at Cranbrook and PaddockWoodAdvice and information offered on all services available,including private sectorAssistance with loan and deposit guarantee scheme

Town and Country HousingGroup

Resident Involvement Officers hold educational sessions atTunbridge Wells High School on ‘Leaving Home’ for 10-15 yearolds

Key gaps in provision:• Concern regarding use of Bed & Breakfast (B&B) as temporary accommodation for

young people as there is no support available.• Little support to prevent homelessness, especially amongst 16/17 year olds. This results

in young people losing tenancies/temporary accommodation.• Lack of life skills training for young people.• Lack of suitable affordable move-on accommodation – across private and social tenures.• Lack of emergency accommodation to enable assessment of options available to the

young person.• Lack of co-ordination and information/advice on preventing homelessness in the

Borough, through schools etc.• Difficulties caused to some providers who offer assured shorthold tenancies rather than

licences.• Poor communication between agencies, resulting in a lack of appropriate signposting

and support provision.• Gap in support services to assist young people with mild learning difficulties.• Lack of affordable accommodation in rural areas has driven young people out of the

Borough.

Key recommendations:• Agencies to agree protocol for assisting young homeless people.• Partnership arrangements to target local schools which have a high pupil exclusion rate,

to actively listen to young people to determine opportunities for them to find out aboutservices and increase access.

The gap analysis and recommendations from the research have been used to develop keytargets which have been incorporated within the Council’s Housing Strategy 2006-2011.These are as follows:

What we plan to do

• Agree a protocol with partnership agencies for assisting young homeless people.• Identify and introduce additional housing to reduce the use of Bed & Breakfast (B&B)

accommodation for young people when they are made homeless.

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• Seek suitable affordable housing in rural areas where a local connection is identified.• Increase joint working arrangements to support young people and increase their life

chances through prevention of homelessness presentations to local secondary schools(for Years 10 and 11), good signposting to suitable housing schemes and supportprovision, increasing access options when the young person has learning difficulties.Schools which have a high pupil exclusion rate will targeted as a priority.

• Introduce emergency accommodation schemes to enable an assessment of options tobe undertaken with the young person.

• Seek to develop move-on support for young people leaving supported housingaccommodation which will assist in improving life skills, access to employment andmaintained tenancies.

• Develop the range of housing options for young people to prevent and reduce youngpeople becoming homeless.

Objectives and SMART actions to deliver the plans listed above are summarised in the mainHousing Strategy Action Plan shown at Appendix 1.

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APPENDIX 14 – Tunbridge Wells Borough Council Housing Partnerships

Partnership CommentsWest Kent Partnershipand Housing Sub-group

The West Kent Partnership includes representatives of the public, private and voluntary sector from the districts ofSevenoaks, Tonbridge & Malling and Tunbridge Wells. The Partnership focuses on strategic issues that affect thewhole of West Kent, such as major transport issues; the economy; and housing issues. The West Kent partnershiphas a number of sub-groups, including a Housing sub-group.

Community PlanPartnership

The Tunbridge Wells Borough Community Plan Partnership is a body, consisting of key local organisations, whichcomplements the work of the West Kent Partnership. Its purpose is to drive, develop and deliver the Community Planand its review.

Borough HousingPartnership

The Housing Partnership was developed in July 2005 to enable housing partners to work strategically to address keyhousing issues within the Borough. The Partnership consists of representatives from a number of Registered SocialLandlords (RSLs), private sector landlords, the Southern Private Landlords Association (SPLA), the Borough Council,and other related services such as the Youth Offending Team, Kent County Council Social Services, the ProbationService, the Primary Care Trust, Parish Councils, residents associations and voluntary agencies/advice groups. TheHousing Partnership is a sub-group of the Community Plan Partnership and the Chair provides two-waycommunication between the Partnerships.

The Housing Partnership has been involved in developing this Strategy and once implemented will continue to review,assess and evaluate performance in meeting the targets set out in the Strategy Action Plan. The feedback andlearning provided will be used both locally and corporately to improve the key services provided at the heart of ourlocal communities.

Parish/Town Councilsand Action withCommunities in RuralKent

The Council works in partnership with Parish/Town Councils and Action with Communities in Rural Kent (ACRK –formerly the Kent Rural Community Council) to identify and meet affordable housing needs in rural areas.

Private Landlords The Council has increasingly engaged with private landlords, particularly to support them during the introduction of theHousing Act 2004. We have participated in Kent-wide landlord forums and have steered improvements through localinitiatives such as the West Kent Landlords Forum (which was first held in June 2006, will be held three times a yearand is jointly organised by the Council in partnership with Sevenoaks District Council, Tonbridge & Malling BoroughCouncil and SPLA) and, locally, the Council’s Private Landlords Panel (which first met in April 2006).

The Council provides landlords with six-monthly editions of the Landlord Bulletin and will develop a Tenant Bulletin toensure that information is provided to both parties on an equal basis.

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Partnership CommentsRegistered SocialLandlords (RSLs)

28 RSLs operate within the Tunbridge Wells Borough. The Council works with a number of local RSLs in the followingways:

• all RSLs are invited to attend quarterly housing management liaison meetings to discuss targets and initiativeswhich assist in the management of their housing stock.

• in meeting local housing needs and providing new affordable housing.• to develop a Choice-based Lettings Scheme.• to monitor housing stock asset management plans to ensure delivery of the Decent Homes Standard across all

social housing.• to support preventative action taken to reduce the number of evictions of tenants on grounds of nuisance/anti-

social behaviour.

We have 13 RSL partners in the Tunbridge Wells Joint Housing Register, which provides a single point of access tosocial housing in the Borough. Through this partnership we have revised our housing allocations policy to giveapplicants a greater opportunity to express their choice of accommodation and area.

The Council currently has seven 7 RSL Preferred Partners for the development of new affordable housing: DownlandHousing Association, Hyde Housing Group, Kelsey Housing Association (part of the Dominion Housing Group), MoatHousing Group, Orbit Housing Group, Town & Country Housing Group (incorporating High Weald HousingAssociation) and Warden Housing Association (part of the Home Group).

The Preferred Partners were originally selected by the Borough Council in conjunction with the Housing Corporation in2001 for the four-year period 2002-2006. The Preferred Partner arrangements were reviewed in 2005 and, followingconsultation with the Housing Corporation, were extended until the end of September 2007. All five of the Council’sexisting preferred partners – Kelsey Housing Association, Moat Housing Group, Orbit Housing Group, Town &Country Housing Group and Warden Housing Association – continue to be Preferred Partners, in addition to whichDownland Housing Association and Hyde Housing Group – both of whom currently have stock in the Borough and areapproved development partners of The Housing Corporation – joined the partnership.

All RSL Preferred Partners are required to attend a quarterly joint liaison meeting with the Council and The HousingCorporation to discuss issues of common interest to all parties. In addition, one-to-one meetings are held between theCouncil and each RSL Preferred Partner every six months to monitor progress on specific development schemes.

The Preferred Partner arrangements are due to be reviewed again by the Council before the end of September 2007.

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Partnership CommentsDevelopers The Council is building its working relationship with private developers to encourage sustainable development,

harness new affordable housing and highlight available funding for new and retrospectively-fitted renewable energyinstallations.

In addition, the Council wants developers to embrace sustainable development and works in partnership with the KentEnergy Centre (KEC) to provide advice on available funding streams.

The Council is keen to ensure that future developments are not only environmentally sustainable, but that everyonecan access local services and public transport networks, whilst continuing to be suitable for future generations.Joined-up working with the Council’s Planning Services and developers will encourage the development of quality builthomes using Secured by Design, Lifetime Homes and Eco Homes renewable energies as standard.

Internal Joint Working Effective internal joint working between the various Services/Departments involved in Housing and Housing-relatedServices is also essential.

An internal Affordable Housing Policy officer working group was established in 2004 and which meets bi-monthly toco-ordinate activities in respect of affordable housing development across the Council. The group is attended byrepresentatives of the Council’s Housing, Legal, Planning, Strategy & Development and Finance Services.

Regular (four-monthly) liaison meetings tae place between the respective Heads of Service and Portfolio Holders forHousing and Planning.

In addition, the Council’s Housing Service is represented on internal officer working groups established in respect of:the Community Plan; the Local Development Framework; Strategy Development; Empty Properties/Street Scene;Performance; Equality & Diversity; and Customer Care.

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APPENDIX 15 – Tunbridge Wells Borough Council Housing Key PerformanceIndicators

Indicator 2004/05Actual

2005/06Actual

2006/07Target

2007/08Target

2008/09Target

Comments

National Performance IndicatorsBVPI 64 No. of private sector vacant dwellingsreturned to occupation/demolished as a directresult of action by the local authority

37 15 20 22 25 -

BV76a No. of Housing Benefit claimantsvisited

210 239 190 200 210 -

BV78a Speed of processing new HousingBenefit/Council Tax Benefit claims

21 days 24 days 23days

22.75days

22.50days

-

BV78b Speed of processing changes ofcircumstances for Housing Benefit/Council TaxBenefit claims

5.9 days 6.16 days 6.0days

5.75days

5.5days

-

BV79a Accuracy of processing HousingBenefit/Council Tax Benefit claims

99.2% 99.6% 99% 99% 99% -

BVPI 183a Average length of stay in B&B ofhouseholds with pregnant woman/children

Nil weeks Nil weeks 3 weeks 2 weeks 2 weeks Decommissioning of theCouncil’s one remaininghostel may lead to use ofB&B for a household whohave no belongings in anemergency

BVPI 183b Average length of stay in hostel ofhouseholds with pregnant woman/children

7 weeks 15 weeks 15 weeks 0 0 Aim is to decommissionthe Council’s oneremaining hostel by31/03/07. In 2005/06 onlytwo households wereplaced in hostelaccommodation, one ofwhich remains inoccupation

BVPI 202 No. of people sleeping rough on aparticular night

New BVPI2004/05

5 5 5 5 Rough sleepers count tobe undertaken 2006/07,following which target tobe reviewed

BVPI 203 % change in average no. ofhouseholds with pregnant woman/childrenplaced in temporary accommodation

-20.86% +31.78 -75% -25% -15% -

BVPI 213 No. of households who consideredthemselves as homeless who approached theCouncil’s Housing Advice Service, and forwhom housing advice casework interventionresolved their situation

New BVPI2005/06

New BVPI2005/06

35 40 45 -

BVPI 214 – Proportion of households acceptedas statutorily homeless who were accepted asstatutorily homeless by the same Authoritywithin the last 2 years

New BVPI2005/06

New BVPI2005/06

1% 1% 1% -

Local Performance IndicatorsNo. of homes achieving Decent HomesStandard as a direct result of Council action

NewLocal PI2005/06

NewLocal PI2005/06

48 180 180 Monitoring systems still tobe developed with partneragencies (in touchTunbridge Wells HomeImprovement Agency andKent Energy Centre) toverify that homesbenefiting from energyefficiency works are beingraised to the DecentHomes Standard as aresult

Year on year % change in no. of homelessacceptances presented monthly

NewLocal PI2005/06

NewLocal PI2005/06

-15 -15 -15 % change was -35% in2005/06 but only -16% in2004/05

Minimum no. of new affordable homesoccupied this year

NewLocal PI2005/06

NewLocal PI2005/06

81 127 141 Annual targets based onestimated completionsunder Affordable HousingDevelopment Programme

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APPENDIX 16 – Housing Strategy 2001-2006 Action Plan Performance Update @ End March 2006

Priority Actions Detailed SMART Targets Performance UpdateMeeting the needs of all our customersProvide 2,900 additional newhomes by 2011

- Forecast: Net DwellingsSurplus completions form 07/1991-04/2001= 34Completions 04/2001-04/2006 = 1,595Net planning permissions at 04/2006 = 1,402Estimate of additional unidentifiedpreviously developed sites 2006-2011 = 540Housing allocations on previouslydeveloped sites* = 360TOTAL FORECAST PROVISION = 3,931

*Excludes 200 dwelling allocation at Kent & Sussex hospital site which isexpected to come forward for planning permission before 2011, but it isunlikely that any dwellings will be completed on site in that timescale

50% of all new homes to be ofsmall or intermediate size, to reflectdemographic changes

- 2001-2006 = 36.45% completed units small / intermediate size(2005-2006 = 50.78% completed units small / intermediate size)

At 31 March 2006, 57.06% of all dwellings subject of outstandingplanning consent were small or intermediate in size. Consequently themost recent year’s completion is on target and the outstanding consentsexceed it

85% of development to be onbrownfield sites to reflect thedemand for urban versus rural sitesin our housing policy

- 93.67% of developments 2001-2006 on brownfield land sites(2005-2006 = 97.3% completions on brownfield land sites)

NB: Local Plan Review target was revised and increased to 90% (so metand exceeded)

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Priority Actions Detailed SMART Targets Performance UpdateMeeting the needs of all our customers (cont)

Provide 35 key worker homes by2004

- No. of key worker homes provided 2001-2006 = 59

Complete research into the needsfor supported accommodation,nursing homes and key workerhousing by 2006

- Research into the need for supported housing was undertaken by KentCounty Council Social Services Department in 2004/05. The researchidentified the need for 40 units extra care sheltered housing for frail olderpeople in Tunbridge Wells Borough. TWBC is part of consortium of Kentlocal authorities an expression of interest under Housing Private FinanceInitiative (PFI) Round 5

In 2005 the West Kent Partnership Housing Sub-Group published goodpractice documents defining ‘local employee’ (key worker) housing, andis now looking to develop an overall approach and pilot projects thatcould form the basis of a West Kent-wide scheme in the future. Thisresearch was funded via a Housing Corporation Innovation and GoodPractice (IGP) Grant

Monitor and provide anassessment of housing needs

Two rural surveys per year Rural surveys undertaken:2002/03 = 3 no.2003/04 = 1 no.2004/05 = 1 no.2005/06 = 4 no.

Wef April 2006, minimum of 2 rural surveys to be undertaken under a 5-year rolling programme, in partnership with Parish/Town Councils andAction with Communities in Rural Kent (ACRK) rural housing enabler

In addition, Borough-wide Housing Needs Survey and Borough-wideGypsy and Travellers’ Accommodation Needs Survey completed 2005

Produce and implement aHomelessness Strategy by March2003

- Homelessness Strategy produced July 2003. Strategy reviewed atregular meetings of Homelessness Strategy Group. New Strategy for2006-2009 currently being developed in conjunction with SevenoaksDistrict Council and Tonbridge & Malling Borough Council

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Priority Actions Detailed SMART Targets Performance UpdateHelping people access homesComply with the DisabilityDiscrimination Act 1995

- Portable hearing induction loop available for use at Housing ReceptionCounter and Housing Interview Rooms. Temporary measures to beactioned by July 2006 to ensure that Housing Reception Counter isDisability Discrimination Act compliant for wheelchair users

Work with RSL partners toprogress a choice based lettingsscheme to social housing

- Cabinet approval given March 2006 to join Mid & East Kent Choice-based Lettings consortium which has been awarded ODPM funding.Scheme due to become operational in 2007

Enable 85 units per year 2001-2006 = 281 affordable homes delivered

NB: Following receipt of the Local Plan Inquiry Inspector’s report thetarget of 815 affordable has been deleted from the Local Plan Review

Facilitate the provision of anadditional minimum 815 affordablehomes between 2001-2011

To provide new affordable homesthrough greater utilisation of emptyhousing stock – 10 units per year

2004/05 = 2 empty properties brought back into use as affordablehousing

NB: To increase future use of empty homes, research was undertakenSummer 2005 to identify long-term vacant properties (those vacant for >6months) in partnership with Council Tax Team. Results of initial study =409 privately-owned long-term empty properties. Letter and investigationquestionnaire sent to each owner December 2005 (approx. 30%response rate to date). Empty Homes Strategy developed as part of newHousing Strategy 2006-2011

Influence the location, size, tenureand type of housing to matchhousing needs

- Location of new housing development dictated by National, Regional andStructure planning policies in support of sustainable developmentpatterns – majority of housing development within urban areas and onbrownfield land sites. Enabling Policy H5 in Tunbridge Wells Local Plan2006, and allocation Policies H6 and H7

Reduce homelessness throughpositive early intervention and thequality of advice and assistance

- 2003/04 = 511 homeless applications / 257 acceptances2004/05 = 413 homeless applications / 230 acceptances2005/06 = 285 homeless applications / 141 acceptances

Reduction achieved due to separation of Housing Advisor role, to enableearly intervention, and increased resources through ODPMHomelessness Grant to fund additional Housing Advisor post

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Priority Actions Detailed SMART Targets Performance UpdateHelping people access homes (cont)Process homeless applicationspromptly and within time limitsspecified in the HomelessnessCode of Guidance

90% of applications to beprocessed within 33 days

2003/04 = 86%2004/05 = 87%2005/06 = 82%

Reduce the use of bed andbreakfast accommodation andeliminate its use for families

Homeless families only placed inB&B in an emergency and wherethey are placed in suchaccommodation it should not be formore than six weeks

No families or pregnant women have been placed into sharedaccommodation B&B since April 2004

Reduction achieved by increasing portfolio of temporary accommodation,through utilisation of Private Sector Leasing Scheme, and introduction ofRent in Advance/Deposit Loan Scheme funded through ODPMHomelessness Grant funding

Develop a policy to address thefunding issues around affordablehousing, including disposal ofCouncil-owned land

- 1st draft of Policy produced January 2005. Reviewed by AffordableHousing Policy Group following publication of Local Plan ReviewInspector’s Report June 2005. Policy will develop into AffordableHousing Supplementary Planning Document (SPD) – target date late2006/early 2007. Policy could not be progressed prior to publication ofLocal Plan Review Inspector’s Report and draft Affordable HousingSupplementary Planning Document (SPD) needed to be reviewedfollowing publication of draft PPS3 by ODPM December 2005 results of2005 Borough-wide Housing Needs Survey results

Develop agreed improvedcollaborative and information-sharing mechanisms withPlanning/Finance/Legal andHousing Services

- Affordable Housing Policy Officer Group established November 2004 –meets bi-monthly and includes representatives of Housing, Planning,Strategy & Development, Legal and Finance

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Priority Objectives Detailed SMART Targets Performance UpdateHelping people live in the communityWork in partnership to identify andaddress the housing and supportneeds of vulnerable residents in thecommunity

Joint Assessment and ReferralScheme (JARS) to be set up toensure vulnerable groups inhousing need are able to accessspecial or general needs housingand are able to maintain a tenancy

Compile an Older Persons’Housing Strategy – by March 2004

Compile a Young Persons’ HousingStrategy – by March 2004

JARS established December 2003 – identified as an example of positivepractice within Audit Commission Housing Inspection report February2006

TWBC’s 2005 Housing Needs Survey and the Kent Supporting PeopleStrategy 2005-2010 identify the needs of older people, both within andmigrating to the Borough. Housing Strategy 2006-2011 takes intoaccount the needs of older people. Key activities and targets have beenset to ensure that their needs are met

A market research study was undertaken in 2005, the results of whichcorrelated to research undertaken to inform the Kent Supporting PeopleStrategy 2005-2010. The report was received July 2005 and presentedto the Homelessness Strategy Group for comments October 2005

Housing Strategy 2006-2011 takes into account the needs of youngpeople and provides key activities and targets to ensure their needs aremet. The research has also informed TWBC’s Children and YoungPeople’s Action Plan activities 2006-2009. TWBC’s new HomelessnessStrategy, in partnership with and Sevenoaks District Council andTonbridge & Malling Borough Council, will also focus on the need toprevent young people becoming homeless

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Priority Objectives Detailed SMART Targets Performance UpdateHelping people live in the community (cont)Fund and support a range ofservices including:- the Home Improvement Agency- Lifeline services- Fuel Poverty- Mediation- Floating Support services

- Home Improvement Agency (HIA) – Care & RepairNew contract with in touch/Hyde Housing Group agreed to operate HomeImprovement Agency services wef April 2006. TWBC revenue funding of£45,320 agreed for 2006/07

Lifeline ServicesNot funded directly by TWBC, but services supported. Clients providedwith service details via HIA and TWBC partnership

Fuel Poverty:Ongoing Service Level Agreement with the Kent Energy Centre

MediationFamily mediation services funded through ODPM Homelessness Grantfunding

Floating SupportNot funded directly by TWBC, but services supported through our role asa Supporting People Commissioning Body partner. Referrals made forsupport services for homeless households in temporary accommodationand through Joint Assessment Referral Scheme (JARS)

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Priority Objectives Detailed SMART Targets Performance UpdateHelping people live in the community (cont)To ensure that existing services areeffective through regular reviews,and to champion new initiativeswhich meet our priorities

- ExamplesDisabled Facilities Grants:- 2004/05 following review and forecasting, supplementary funding

agreed by Cabinet to meet increased need- 2005/06 Government Office for the South East (GOSE) confirmed

supplementary funding, match-funded by TWBC, total increase infunding of £33,334

- Increased TWBC capital funding of £310,000 agreed for 2006/07

New services introduced:- Rent in Advance/Deposit Loan Scheme funded through ODPM

Homelessness Grant Funding- Private Sector Leasing Scheme- Housing advice surgeries at Town Hall and in rural areas

New services under development:- TWBC led a consortium of 11 Kent local authorities to develop a joint

approach for a Council-endorsed equity release and loan scheme(HouseProud) to assist elderly or disabled owner-occupiers afford homeimprovements. The scheme will help households who do not meet theCouncil’s Home Improvement Grant eligibility criteria and requirerepairs/adaptations to the property, which cost a minimum of £3000.Contract signed with Home Improvement Trust May 2006. The schemeis due to be launched August 2006

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Priority Objectives Detailed SMART Targets Performance UpdateImproving the quality of our homesIn the public sector, to work withRegistered Social Landlord (RSL)partners on their strategies forachieving the Decent HomesStandard target and to monitor theirprogress

All Social Housing to meet theDecent Homes Standard by 2010

Monitoring of RSLs’ progress in meeting Decent Homes Standard beingmonitored via RSL Housing Management Liaison Group establishedOctober 2005 and which meets quarterly. Details of RSL’s AssetManagement Strategies requested

In the private sector, through grantand enforcement activities, andliaison with landlords to improvestock quality

Improve 75 properties per yearthrough grant funding andenforcement action

Home Improvement Grants for home repairs and energy efficiency2001/02 – Renovation = 51, Home Repairs Assistance = 402002/03 – Renovation = 31, Home Repairs Assistance = 332003/04 – Renovation = 31, Home Repairs Assistance = 11

Following the introduction of the Regulatory Reform (Housing Assistance)(England and Wales) Order 2002, there was a continued reduction infunding and subsequent change in grant policy towards private sectorstock improvements

2004/05 – Home Improvement Grants = 222005/06 – Home Improvement Grants = 32

Disabled Facilities Grants2001/02 = 272002/03 = 232003/04 = 422004/05 = 682005/06 = 76

Enforcement activities (Formal Notices complied with)2001/02 = 162002/03 = 202003/04 = 412004/05 = 152005/06 = 41

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Priority Objectives Detailed SMART Targets Performance UpdateImproving the quality of our homes (cont)In the private sector, through grantand enforcement activities, andliaison with landlords to improvestock quality

Improve 75 properties per yearthrough grant funding andenforcement action

Empty homes brought back into use2001/02 = n/a2002/03 = 82003/04 = 32004/05 = 372005/06 = 15

Assist 150 clients per year throughCare & Repair

No. of clients receiving advice from Care and Repair2001/02 = n/a2002/03 = 1032003/04 = 2732004/05 =2092005/06 = 607

Care and Repair advice sessions held2001/02 = n/a2002/03 = n/a2003/04 = 62004/05 = n/a2005/06 = 10

In the private sector, through grantand enforcement activities, andliaison with landlords to improvestock quality

Help 300 clients per year accessthe Handyperson scheme

2001/02 = n/a2002/03 = n/a2003/04 = 4572004/05 = 4022005/06 = 159 (NB: Handyperson service has been affected by a periodof long-term sickness which has restricted outputs)

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Priority Objectives Detailed SMART Targets Performance UpdateImproving the quality of our homes (cont)

Improve physical and livingconditions of the Borough’shousing stock by:

Inspecting 40 Houses in MultipleOccupation (HMOs) per year andbringing 20 HMOs up to thefitness standard per year

HMOs Inspected2001/02 = 82002/03 = 342003/04 = 112004/05 = 122005/06 = 11

HMOs brought up to standard2001/02 = 152002/03 = 122003/04 = 132004/05 = 122005/06 = 10

NB: the reduction in activity is the result of a change in the duties andpowers to undertake enforcement in regards to owner-occupied self-contained flats and staffing issues within TWBC’s Private Sector Housing& Initiatives Team

In the private sector, through grantand enforcement activities, andliaison with landlords to improvestock quality

Develop and implement a PrivateSector Renewal Strategy byMarch 2004

Strategy formally adopted by Council April 2005

Across all sectors, to reducedomestic energy use throughpromotional activities, advice anddiscount schemes

Statutory duty to reduce energyconsumption under Home EnergyConservation Act 1995 – target toreduce energy consumption by30% on 1996 levels by 2011

1997-2005 = 18.14% reduction2005/06 figures not available until July 2006TWBC is on target to achieve 30% reduction by 2011

NB: Kent Health & Affordable Warmth Strategy – A Plan of Action 2005-2008, adopted by TWBC 2005

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APPENDIX 17 – Glossary of Abbreviations and Housing Terms

ACRK Action with Communities in Rural Kent – formerly the Kent RuralCommunity Council. An independent voluntary organisation which:provides direct advice and support to community organisations;stimulates community action, particularly voluntary action, andencourages good practice; develops and manages demonstrationprojects; provides professional support and advice to key serviceproviders; and raises awareness of rural issues and influence decisionmakers

Affordablehousing

Housing which is accessible to people whose income does not enablethem to afford to buy or rent appropriate local housing for their needs onthe open market

Best Value The means by which the Council is held accountable for the efficiencyand cost effectiveness of its service provision and its proposals toimprove on those services

CAB Citizens’ Advice Bureau – voluntary organisation providing advice to thepublic on employment, housing, immigration/nationality, consumer debt,and welfare rights. The Tunbridge Wells & District Citizens AdviceBureaux have three bureaux located in Cranbrook, Paddock Wood andTunbridge Wells

Choice-basedLettings

System for allocating social housing which provides an opportunity forpeople seeking social housing to choose which properties they wish tobe considered for to a greater extent than traditional Housing Allocationsystems

CLSP Community Legal Services Partnership – partnership which bringstogether organisations offering legal and advice services, such assolicitors in private practice, Citizens Advice Bureaux, Law Centres, localauthority in-house services as well as representatives of the LegalServices Commission. All the partners act together to improve access to,and delivery of, legal and advice services in their local community. Morethan 200 Community Legal Service Partnerships have been establishedacross England and Wales

Community Plan Strategic document developed by the Local Strategic Partnership (LSP)to improve local services and to meet the needs and aspirations of localpeople. The aim of the Community Plan is to promote the economic,social and environmental well-being of the Borough

CO2 Carbon dioxide – a major contributor to global warmingCPA Comprehensive Performance Assessment – assessment process

introduced by the Audit Commission in 2002 as a tool to form ajudgement about the performance of councils and their arrangements forimproving services

Decent HomesStandard

Government definition of Decent Housing published in 2002. To bedefined as a ‘decent home’, a property must: meet current statutoryminimum for housing; be in a reasonable state of repair; have reasonablymodern facilities; and provide a reasonable degree of thermal comfort(effective insulation and heating).

DFG Disabled Facilities Grant – a mandatory grant made available by localhousing authorities to disabled persons to provide adaptations to theirproperty to enable them to continue living independently in their home.The grant is available to owner-occupiers and tenants

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Disrepair A property could have been recorded as ‘fit for human habitation but insubstantial disrepair’ because it failed to meet one or more of therequirements under the Fitness Standard (see ‘Unfit housing’). Frequentcauses of substantial disrepair included lack of repair, dampness andpoor condition/inadequate food preparation facilities

DIYSO Do-It-Yourself Shared Ownership – former scheme funded by theHousing Corporation to provide cash grants to assist people in housingneed to purchase a share of a home on the open market on a partrent/part buy basis

Eco Homes An environmental assessment method for home which addresses arange of environmental impacts such as energy, transport, pollution,materials, water, land use and ecology, health and well-being

EEC Energy Efficiency Commitment – funding provided by the fuel utilities forenergy efficiency improvements, mainly insulation, by approvedinstallers. 100% grants are available for priority households in receiptone of the principal income or disability-related benefits. Partial grantsare available for other households. The value of EEC funding varies andis linked to the carbon savings of the installed measures

Every ChildMatters

Central Government programme aimed at transforming children'sservices. The Children Act 2004 provides the legal underpinning for‘Every Child Matters: Change for Children’. A series of documents havebeen published which provide guidance under the act, to support localauthorities and their partners in implementing new statutory duties. Well-being is the term used in the Act to define the five Every Child Mattersoutcomes which are: be healthy; stay safe; enjoy and achieve; make apositive contribution; and achieve economic well-being

Floating support A scheme under which vulnerable people living in their own self-contained accommodation receive housing-related support from visiting(‘floating’) support workers

Fuel poverty Where people cannot afford to heat their homes to an acceptablelevel at a reasonable cost i.e. 10-20% of their disposable income

GOSE Government Office for the South East. Co-ordinates regional operationsacross the South East for a range of central Government departments

HHSRS Housing Health & Safety Rating System – new system for assessinghousing conditions and determining enforcement action which replacedthe Fitness Standard with effect from April 2006. An assessment of thedwelling will involve a physical survey of the property noting the hazards.There are 29 listed hazards which will be classified according to thelikelihood of the harm occurring and the severity of the harm, as eithercategory 1 or category 2, following a complex calculation

HMO House in multiple occupation – a property which is occupied by personswho do form a single household, e.g. a house which is subdivided intosmall flats or bedsits with shared facilities

Home EnergyConservation Act(HECA) 1995

Requires local authorities to develop strategies leading to a significantreduction in domestic energy consumption in their areas by 2010 and toreport annually on progress made. A ‘significant’ reduction is defined as30%

HomeImprovementAgency

A not-for-profit organisation which assists older, disabled and othervulnerable people to have adaptations and repairs/improvements carriedout to their homes to enable them to remain in the homes. TheTunbridge Wells Home Improvement Agency is in touch, part of the HydeHousing Group

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HomeImprovementGrant

A discretionary grant made available by the Council under its HousingRenewal Assistance Policy to vulnerable householders to fundrepairs/improvements to their homes

Home RepairAssistance

A discretionary grant made available by local housing authorities underthe Housing Grants, Construction & Regeneration Act 1996 to vulnerablehouseholders to fund repairs/improvements to their homes. Repealedunder the Regulatory Reform (Housing Assistance) (England and Wales)Order 2002

Homebuy Scheme funded by the Housing Corporation to provide cash grants toassist people in housing need (including key workers) to purchase ahome on the open market

House ConditionSurvey

Survey carried out by the Borough Council to determine the assess thecondition of housing within the Borough including the cost of worksneeded to bring homes to the Decent Homes Standard

HousingCorporation

The public body responsible for funding new affordable housing providedby Registered Social Landlords (RSLs) and for regulating the activities ofRSLs

Housing NeedsSurvey

Survey carried out by the Borough Council to determine the housingneeds of the Borough including the need for affordable housing

Housing Register A list maintained by the Borough Council of households requiringaffordable housing

HSSA Housing Strategy Statistical Appendix – annual statistical return whichlocal housing authorities are required to provide to central Government

IGP Grant Innovation and Good Practice Grant – grant made available by theHousing Corporation to fund projects to promote innovation and goodpractice amongst Registered Social Landlords (RSLs) and their partners

JARS Joint Assessment Referral Scheme – scheme established in December2003 to determine options and support packages for people moving inand out of supported housing in the Borough. This brings together a widerange of stakeholders, including staff from Registered Social Landlords(RSLs), supported housing providers, the Youth Offending Team (YOT)and Social Services care managers

KASH Kent Action to Save Heat – discount insulation and heating schemeoperating across Kent, set up by KEEP with the aid of a GovernmentHECAction grant. The scheme is managed by the Kent Energy Centre(KEC)

KCC Kent County Council – the statutory authority responsible for servicessuch as Social Services and Education

KEC Kent Energy Centre – a not-for-profit organisation that is one of anetwork of 50 local energy advice centres. KEC was set up in 2000 andis funded primarily by the Energy Saving Trust and all thirteen of Kent’slocal authorities. KEC works in close partnership with the authorities tohelp achieve the targets under HECA, provide free energy advice to allKent households and reduce domestic energy consumption

KEEP Kent Energy Efficiency Partnership – the consortium of all Kent localauthorities working together to co-ordinate projects, share information,improve domestic energy efficiency and reduce domestic energyconsumption

Key workers Key public sector employees in the Health, Police, Social Care, Teachingand Fire Service sectors who have a housing need

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LAA Local Area Agreement – an agreement (alongside a Local Public ServiceAgreement) between the Kent local area and central Government. It wasestablished through Kent County Council (KCC), working with the KentPartnership and other local partners. The intention of the agreement is todrive further improvements to services to local people in Kent from 2005-08. The LAA comprises a set of 18 agreed outcomes with an ambitiouswork programme. Outcome 17 is ‘to improve Kent residents' access tohomes of excellent quality, in the right place, at the right time and at rightcost’, and includes targets for the delivery of new affordable homesacross Kent

LASHG Local Authority Social Housing Grant – formerly capital grant fundingpaid by local housing authorities to Registered Social Landlords (RSLs)to support the development of new affordable homes. Grants paid bylocal housing authorities were reimbursed in full by the HousingCorporation. LASHG was abolished with effect from April 2003

LDF Local Development Framework – new system of preparing developmentplans, introduced under the Planning and Compulsory Purchase Act2004. Structure plans and local plans are to be replaced by RegionalSpatial Strategies (RSSs) and LDFs. LDFs are a combination ofDevelopment Plan Documents (DPDs) which collectively deliver thespatial planning strategy for the local planning authority's area

Local Plan Strategic document published by local planning authorities – includingTunbridge Wells Borough Council – setting out policies and guidance forfuture development within its area

Local housingauthority

Local authorities with the statutory responsibility for housing matters. Intwo-tier local government areas such as Kent (excluding Medway, whichis served by a unitary local authority, Medway Council) the district/borough councils – including Tunbridge Wells Borough Council – arelocal housing authorities

Low cost homeownership

A range of initiatives which result in housing for sale at a lower price thanthe average open market price. Includes schemes such as sharedownership

LSP Local Strategic Partnership – a body consisting of key local organisationswhose is to drive, develop and deliver the Community Plan and itsreview. The Tunbridge Wells Borough LSP is known as the CommunityPlan Partnership

LSVT Large Scale Voluntary Transfer – where a Council transfers its socialhousing stock to a Housing Association or Registered Social Landlord(RSL). Tunbridge Wells Borough Council is an LSVT Authority havingtransferred its stock to High Weald Housing Association (now part of theTown & Country Housing Group) in 1992

ME Minority Ethnic – people from black, Asian and ethnic minoritycommunities

OPDM Office of the Deputy Prime Minister – central Government departmentestablished in 2002 which had responsibility for national policy andguidance on local government, housing and planning. Replaced by theDepartment for Communities & Local Government (DCLG) in May 2006

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OT Occupational Therapist – qualified professionals who deal with caseswhere the service user has complex or multiple needs. OT's work in thecommunity seeing people in their own homes where appropriate andassessing their needs according to their circumstances. The role of KentCounty Council’s OT Bureau is to assess the needs of people of all ageswho have difficulty managing activities of daily living due to a physicaldisability or frailty for special equipment and/or adaptations to theirhome, which will increase their control over the practical aspects of theireveryday life

PCT Primary Care Trust – part of the National Health Service responsible forproviding local primary care and General Practitioner (GP) services

PFI Private Finance Initiative – Government scheme through which largepublic sector building projects can be delivered using private finance

PSL Private Sector Leasing – scheme whereby private sector properties areleased by the Council for use as temporary accommodation for homelesshouseholds

Purchase &Repair

Scheme whereby a Registered Social Landlords (RSL) purchases aproperty on the open market and carries out repairs/improvements priorto reletting as affordable housing

RSL Registered Social Landlord – non-profit making housing organisationsmanaging and developing affordable housing. Most are housingassociations registered with the Housing Corporation

Rural exceptionsite

Plot of land in or on the edge of villages in rural areas allocated for thedevelopment of affordable housing for local people which would nototherwise be granted planning permission for open market housing

SAP Rating Standard Assessment Procedure Rating – an assessment of the energyefficiency of a property within a scale of 1-100. The more energy efficienta property is the higher the SAP rating

SCG Specified Capital Grant – capital grant funded by central Governmentand paid to local housing authorities to meet part of the cost of fundingDisabled Facilities Grants (DFGs)

Section 106agreement

Legal agreement under Section 106 of the Town & Country Planning Act1990. Used as a means of securing the provision of affordable housingwithin private housing developments

SEERA South East England Regional Assembly – grouping of all South Eastlocal authorities with economic and social partners (businesses,voluntary agencies) set up and funded by central Government topromote the South East England region. SEERA is the regional planningbody responsible for the South East Plan and, with effect from April2006, the South East Regional Housing Strategy

Sharedownership

A form of affordable housing where the householder buys a share of theproperty and rents the remaining share, traditionally from a RegisteredSocial Landlord (RSL). In some cases it is possible for the householderto buy further shares of the property up to 100% ownership. See also‘Low cost home ownership’

SHG Social Housing Grant – Housing Corporation capital grant paid toRegistered Social Landlords (RSLs) to fund the development of socialhousing

SMART targets Specific, measurable, achievable, relevant, timetabled targetsSouth EastRegionalHousing Board

The public strategic body responsible for allocating public funding toRegistered Social Landlords (RSLs) and local authorities for housinginvestment in the South East

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Social housing Subsidised housing provided by a local authority or Registered SocialLandlord (RSL)

SPD Supplementary Planning Document – document issued under the LocalDevelopment Framework (LDF) process setting out Planningpolicy/guidance on a specific topic, e.g. affordable housing

SPLA Southern Private Landlords Association – a not-for-profit organisationrepresenting good residential landlords throughout Southern England.The Association actively seeks to achieve and maintain qualityaccommodation for rent and high standards of management in theprivate rented sector, whilst protecting and furthering landlords' interestsat both local and national level. SPLA offers landlords convenient accessto a range of information, advice, services and support, which they wouldhave difficulty finding elsewhere

Starter HomesInitiative

Former scheme funded by the Housing Corporation to provide cashgrants to assist key workers to purchase a home on the open market

Supportedhousing

Specialist housing for client groups in need of accommodation withsupport, e.g. people with a learning disability

SupportingPeople

An integrated policy and funding framework for the provision of housing-related support to vulnerable introduced in 2003. Supporting Peoplegrant is a revenue grant funded by central Government but administeredby local authorities. In Kent, the Supporting People programme isadministered by the Kent Supporting People Team within Kent CountyCouncil

Unfit housing A property was considered unfit for human habitation if it failed to meetone or more of the requirements of the Fitness Standard laid down inSection 604 of the Housing Act 1985 as amended by the LocalGovernment & Housing Act 1989 and by reason of that failure was notreasonably suitable for occupation. The Fitness Standard was replacedby the Housing Health & Safety Rating System (HHSRS) which wasintroduced under the Housing Act 2004 in April 2006

Warm Front A Government-funded grant scheme (administered by EAGA) to provideheating and insulation to certain vulnerable households (e.g. over 60s,families with young children etc) in receipt of one of the principal incomeor disability-related benefits. The Kent Energy Centre (KEC) can provideinformation on the qualifying criteria and make referrals to the scheme.Maximum grant available is currently £2,700 (2006)

YOT Youth Offending Team – part of the Kent Youth Offending Service(YOS). There is a YOS in every local authority in England and Wales.They are made up of representatives from the Police, Probation Service,Social Services, Health, Education, Drugs and Alcohol Misuse andHousing Officers. Each YOT identifies the needs of individual youngoffenders by assessing them using a standardised national assessmentguide. It identifies the specific problems that make the young personoffend, as well as measuring the risk they pose to others

Zone agent A Registered Social Landlord (RSL) appointed by the HousingCorporation to market low cost home ownership schemes (includingthose for key workers) across a sub-regional area. The zone agent dealswith applications and assesses eligibility for such schemes. MoatHousing Group is the ‘zone agent’ for Kent

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APPENDIX 18 – List of Consultees

[TO FOLLOW]