Delegation of Housing Management
September 2002
The Association of Chartered Certified Accountants (ACCA) is pleased to have this opportunity to comment on the Delegation of Housing Management (the consultation paper). These comments have been prepared in consultation with members of the ACCA's Public Sector Technical Committee, a group of experienced accountants working in the public sector.
The Government's Code of Practice on Written Consultation states that, "Twelve weeks should be the standard minimum period for a consultation". Respondents for the current consultation exercise however, have been given only slightly more than eight weeks. This is particularly significant as the consultation involves amending primary legislation through the use of a Regulatory Reform Order.
Whilst we accept that tenants "will remain tenants of the local authority" (paragraph 6.2 of the consultation paper), the effect of the proposed changes is that local authorities will have far less control or influence over the quality of the services provided to the tenants concerned. This appears to conflict with the intention of Parliament when passing the relevant legislation, which was "that the authority would remain legally, politically and financially accountable for the actions of its agents", as housing managers (paragraph 5.1 of the consultation paper).
In this situation, we believe that council tenants should have as much say in the transfer of responsibilities for housing management as if the council were to transfer it houses to a registered social landlord. Thus tenants should be balloted on their views on the transfer rather than just being consulted (paragraph 4.11of the consultation paper).
Finally we are concerned that the proposed Regulatory Reform Order has only been subject to a partial regularity impact assessment (Annex G) and that the relatively simple changes which are being proposed are contained with in a consultation document which in nearly 50 pages long. This again appears to conflict with the Government's Code of Practice on Written Consultation which states that a "consultation document should be as simple and concise as possible" (Annex E (iii)).