Fill - Free fillable Form 5645 Elmbridge's Response To The Consultation (Elmbridge Borough Council) PDF form

Consultation response pro-forma

A review of local authorities’ relative needs and resources:

Technical consultation

If you are responding to this consultation by email, please reply using this questionnaire

pro-forma, which should be read alongside the consultation document.

You should save the pro-forma on your own device, from which you can complete the

survey at your own pace, and submit by email when you are ready.

There are 16 questions in this form (some with sub-questions). You do not have to

answer every question should you not wish to. The comment boxes will expand as you

type, should you need more space.

Should you wish to attach further evidence or supporting information, you may attach

and send this via email, along with the pro-forma.

Consultation response pro-formas should be returned by email to:

NeedsAndResources@communities.gov.uk

Alternatively if you wish to respond in writing, the relevant contact details can be found

on page 5 of the main consultation document.

Your opinions are valuable to us. Thank you for taking the time to read the consultation

document and respond.

Your Details (Required details are marked with an asterisk (*))

Full Name*

Organisation*

Address*

Address 2

Town/City*

Postcode*

Country

Email address*

Phone Number

Andrew Cooper

Elmbridge Borough Council

Civic Centre, High Street

Esher

KT10 9SD

United Kingdom

Consultation response pro-forma

Are the views expressed on this form an official response from a:

Combined Authority

Fire and Rescue Authority

Greater London Authority

London Borough

Metropolitan District

Parish or Town Council

Shire County

Shire District

Unitary Authority

Local Authority Association or Special Interest Group

Other Local Authority Grouping

Local Authority Officer

Local Authority Councillor

Member of Parliament

Other Representative Group

Business

Business Organisation

Valuation Organisation

Voluntary Organisation

Member of the Public

Consultation response pro-forma

Relative needs

Question 1

Do you have views at this stage, or evidence not previously shared with us, relating

to the proposed structure of the relative needs assessment set out in this section?

Yes

Don’t know

Please specify

Question 2

What are your views on the best approach to a Fire and Rescue Services funding

formula and why?

No comment

Please specify

Elmbridge Borough Council would argue for the exclusion of deprivation from the relative needs' assessment.

The removal of deprivation would greatly simplify the formula. We refer to MHCLG's findings that population

alone accounted for 84% of the difference in local authorities' past expenditure on lower-tier services;

deprivation only explained an additional 0.4% of the difference. Deprivation should only be included in services

where there is evidence that it is a significant cost driver, for example, adult social care and children's services.

We also argue for the removal of additional population on the grounds that it would simplify the formula and

that it currently plays a fairly small role in determining the overall pattern of assessed needs.

We argue for the inclusion of a fixed amount per authority and we believe this should be assigned more weight

in the formula to reflect the lack of economies of scale available to districts such as Elmbridge. In the

consultation document MHCLG asserts that “fixed costs, as well as variable costs, are already identified through

the wider assessment of relative needs.” It is unclear where fixed costs are included, as no other proposed

formula allocates a fixed amount per local authority - they only include a basic amount per resident, which does

not reflect the lack of economies of scale faced by authorities with a smaller number of residents.

✔

Consultation response pro-forma

Question 3

What are your views on the best approach to Home to School Transport and

Concessionary Travel?

No comment

Please specify

Question 4

What are your views on the proposed approach to the Area Cost Adjustment?

No comment

Please specify

We do not believe it is possible to estimate the impact of these changes on individual local authorities.

✔

Consultation response pro-forma

Relative resources

Question 5

Do you agree that the Government should continue to take account of non-

discretionary council tax discounts and exemptions (e.g. single person discount and

student exemptions) and the income forgone due to the pensioner-age element of

local council tax support, in the measure of the council tax base?

Yes

Don’t know

If so, how should we do this?

Question 6

Do you agree that an assumptions-based approach to measuring the impact of

discretionary discounts and exemptions should be made when measuring the council

tax base?

Yes

Don’t know

If so, how should we do this?

We agree that Government should continue to take account of existing non-discretionary elements in the

measurement of council tax base. We also agree that an adjustment should be introduced in relation to the

income forgone due to the pensioner age element of local council tax support. It is also important that these

adjustments are applied annually based on the most up to date information available.

The Council favours an approach that enables the financial impact of local decisions are contained at a local

level. Therefore, an assumptions-based approach should be used to measure the impact of discretionary

decisions. This would assume a common approach has been taken across all authorities in order to avoid taking

direct account of local policy decisions.

Consultation response pro-forma

Question 7(a)

Do you agree that the Government should take account of the income forgone due to

local council tax support for working age people?

Yes

Don’t know

Question 7(b)

What are your views on how this should be determined?

No comment

Please specify

We believe this should be based on a uniform discount rate, expressed as a percentage of each authority's

council tax base. This would avoid creating undesirable incentives, by linking local policy choices (i.e. the level of

LCTS provided to working-age residents) to the amount of funding or retained business rates an authority

received. There is no logic in enabling Councils to have local discretion over such a scheme and then adjusting

for this at national level.

Consultation response pro-forma

Question 8(a)

Do you agree that the Government should take a notional approach to council tax

levels in the resources adjustment?

Yes

Don’t know

Question 8(b)

What are your views on how this should be determined?

No comment

Please specify

Elmbridge Borough Council agree that a notional approach to council tax levels should be taken in the resource's

adjustment, as opposed to actual levels. Using actual levels would impose a larger resource reduction on

councils like us, effectively penalising us for historical decisions that are outside of our control. It would also

create undesirable incentive effects, as councils could potentially secure more funding by lowering council tax

rates. Less funding would also be distributed to areas with higher council tax levels, meaning residents could end

up receiving the same level of public services as elsewhere, despite paying higher taxes.

Consultation response pro-forma

Question 9

What are your views on how the Government should determine the measure of

council tax collection rate in the resources adjustment?

No comment

Please specify

Question 10

Do you have views on how the Government should determine the allocation of

council tax between each tier and/or fire and rescue authorities in multi-tier areas?

Yes

Don’t know

Please specify

We would again argue that the government should use notional or an assumed collection rate rather than actual

collection rates. If actual collection rates were used this could dis-incentivise local authorities from maximising

their rate of collection, as it would result in a larger resource adjustment and lower net funding.

Elmbridge would argue against using actual rates due to the fact it could create unwanted incentive effects, as

setting higher council tax levels could translate to a larger negative resource adjustment and therefore less

funding. Districts with identical tax levels and tax bases could face different resource deductions, due to

different tax levels being set by their respective county councils.

Consultation response pro-forma

Question 11

Do you agree that the Government should apply a single measure of council tax

resource fixed over the period between resets for the purposes of a resources

adjustment in multi-year settlement funding allocations?

Yes

Don’t know

Additional comments

Question 12

Do you agree that surplus sales, fees and charges should not be taken into account

when assessing local authorities’ relative resources adjustment?

Yes

Don’t know

Additional comments

We do not agree that the Government should apply a single measure fixed over a period. Such an approach

increases the likelihood of significant resource changes at the end of each reset period instead of these being

experienced incrementally each year. Elmbridge believe that projections are necessary to ensure that the size of

each authority's resource adjustment is commensurate with the size of its council tax base at any point in time.

The Council recognises with the case set out in the consultation document for taking into account local

authorities' ability to raise sales, fees and charges when assessing local authority relative resources. However,

the arguments against doing this are persuasive ones. The Council's view is that the relatively limited scale of

such income, the challenges measuring it, the degree of potential volatility and disincentive impact on Councils

are such that sales, fees and charges should not be taken into account when measuring relative resources.

Consultation response pro-forma

Question 13

If the Government was minded to do so, do you have a view on the basis on which

surplus parking income should be taken into account?

Yes

Don’t know

Please specify

Legislation already exists for applying surplus parking income and a range of other sources of income. The

Council's view is that it would be inappropriate to treat any of these income sources in an exceptional way.

Consultation response pro-forma

Transitional arrangements

Question 14(a)

Do you agree with the proposed transition principles?

Yes

Don’t know

Please specify

Question 14(b)

Should any other principles be considered by the Government in designing of

transitional arrangements?

No comment

Please specify

Without knowing how our funding will change it is not possible to agree or disagree.

Transition needs to be holistic and transparent and take account of Business Rate gains and other funding such

as New Homes Bonus legacy payments.

Consultation response pro-forma

Question 15

Do you have views on how the baseline should be constructed for the purposes of

transition?

Yes

Don’t know

Please specify

Question 16

Do you have any comments at this stage on the potential impact of the proposals

outlined in this consultation document on persons who share a protected

characteristic? Please provide evidence to support your comments.

No comment

Please specify

We welcome the intention to engage with Councils to arrive at the best measure for setting the baseline.

Elmbridge makes the case for the inclusion of retained business rates, new homes bonus and funding used to

offset negative RSG, in the transition baseline. We argue this on the basis that these reflect the actual cash

available to authorities in 2019/20. We believe these funding streams should be treated no differently from

other sources of revenue.

The content of the consultation does not provide a basis for making any specific comments on this aspect.

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