Consultation Responses

We have responded to the Mayor’s early consultation on the next iteration of the London Plan. We're broadly supportive of the proposed approach to streamline the Plan, which we believe is a positive step towards creating a more effective plan going forward. However, for the next London Plan to succeed in practice, it will be essential for policymakers to adopt a pragmatic approach - one that recognises the wider viability challenges in London, regulatory barriers and the current macro-economic picture.

The short BPF response to the DESNZ call for evidence on solar in car parks and EV infrastructure makes clear that we don't support mandating solar canopies on car parks unless viability challenges are addressed. We welcome proposals to accelerate the installation of EV infrastructure, including through the use of permitted development rights, but stress the need to reform and improve the DNO process to reduce wait times for EV charging connections.

We responded to this joint HMRC and HM Treasury consultation, which proposes to introduce an advanced tax clearance process for those investing in major projects in the UK. We recognise the importance of stability and certainty of tax and regulation for investors. To that end, we fully support efforts to provide greater advanced certainty for major projects and would encourage Government to go further to ensure that tax certainty is prioritised more broadly, beyond only the very largest of investments. 

In our response to the Judiciary’s consultation on the new Practice Statement for Part 26A Restructuring Plans under the Companies Act, we highlight the need for proper information disclosure to make the process fairer, less costly, less adversarial and to promote engagement. We recommend a number of ways to achieve this including a standard list of information to be disclosed and also standardised NDAs.

The BPF's response to HM Treasury on it consultation on regulations for alternative investment fund managers. We welcome proposals to simplify the regulatory framework for AIFMs, while retaining core consumer market protections.

The BPF's response to the Financial Conduct Authority's (FCA) 'call for input' on the future regulation of alternative fund managers. We support the FCA’s call for input to better support firms to grow, compete, innovate, and enter the market - while protecting customers and encouraging firms to manage risk responsibly.

Our response highlights concerns over the proposed EPC reforms and the timing of the minimum energy efficiency standards (MEES) consultation. Without clarity on the new domestic EPC metrics and methodology, it's impossible to provide a full response to key questions in the consultation. As such, we cannot support the Government’s proposals on future MEES at this stage. We want to see further consultation once both the EPC and MEES consultation responses have been published in full.

In our response to the Transforming Business Rates consultation, we highlight the need for Government to work towards a fairer and more responsive business rates system. This includes introducing more frequent revaluations, lowering and fixing the tax rate and ensuring that Empty Property Relief adequately reflects typical re-occupation periods.

Our response strongly supports no changes to non-domestic EPCs and highlights a range of challenges with the proposed changes to domestic EPCs. If the changes go ahead, we call for appropriate transitioning measures (including sufficient lead-in times and the “grandfathering” of existing EPCs) and ongoing engagement with the sector, particularly given the links to MEES.

In our response, we set out our thoughts on the Government’s proposals to introduce permitted insurance fees for landlords, freeholders and property managing agents. We support transparency, and easier access to challenging unreasonable charges, but express concerns about the loss of a portfolio approach and unintended consequences this may have on consumers. We also acknowledge that many members will already be regulated by the FCA and should therefore should not face these proposals. We caution heavily against a cap, which would lead to distortions in service provision or fees charged, and instead suggest greater data is made available on fees charged.

Our response to the Law Commission's review of the Landlord & Tenant Act 1954 recommends shifting to a contracted-in approach and removing security of tenure for leases of five years or less. We also highlight how reforming the Act would support redevelopment, refurbishment, decarbonisation and economic growth.