Consultation response pro-forma
1
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
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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
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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
No
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
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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
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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
No
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
No
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.
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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
No
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.
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Question 8(a)
Do you agree that the Government should take a notional approach to council tax
levels in the resources adjustment?
Yes
No
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.
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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
No
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
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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
No
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
No
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
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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
No
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
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Transitional arrangements
Question 14(a)
Do you agree with the proposed transition principles?
Yes
No
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
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Question 15
Do you have views on how the baseline should be constructed for the purposes of
transition?
Yes
No
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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