Consultation Responses

The BPF has responded to MHCLG’s consultation on social rent convergence. In our response, we welcome the government’s proposals, recognising that a clear and predictable approach to rent convergence can help build investor confidence in the private rented sector. 

We responded to the Welsh Government’s proposals to introduce a lower multiplier for retail properties below £50k rateable value, to be funded with a higher multiplier on properties values above £100k. We expressed concern that these measures would add complexity to the system and risk distorting commercial decisions around new ‘cliff-edge’ thresholds. We also raised concerns in relation to the impact these measures could have on businesses that use large or expensive properties - which is likely to include a number of our growth sectors that are being championed in the Industrial Strategy like advanced manufacturing, lab space, data centres and more. We're concerned these measures could have an adverse impact on our potential for economic growth which would be damaging for our high streets.

The BPF welcomes the Government’s proposal to introduce a national scheme of delegation, which should create greater consistency in determining which applications are referred to planning committees and which are decided by officers. However, our response highlights that the opportunity to drive more meaningful improvements in how planning committees operate has not yet been fully grasped - particularly the need to encourage committees to make greater use of expert opinion in their decision-making.

The BPF has responded to MHCLG’s consultation and working paper on speeding up build-out rates. In our response, we highlight the key role that purpose-built rental housing can play in accelerating delivery as part of a multi-tenure approach to development. We also set out our concerns regarding the proposed Delayed Homes Penalty, which, if introduced, risks further disincentivising investment in residential development and undermining wider housing delivery.

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.

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. 

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.

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 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.

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.

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.