Matthew Pennycook
MP for Greenwich and Woolwich · Labour · United Kingdom
“It is a pleasure to serve with you in the Chair, Dame Siobhain. I congratulate the right hon. and learned Member for Kenilworth and Southam (Sir Jeremy Wright) on securing this debate.”
“I will address the right hon. and learned Gentleman’s specific question in due course. Before I do so, I want to put on the record the policy in relation to villages. He can rest assured that I will address the point; if he is unsatisfied, he is more than welcome to intervene again. A number of hon. Members mentioned villages.”
“I will say two things in respect to that, and I will come on to detail how the approach works in relation to decision making very shortly. In general terms, developers can make whatever claims they like about any particular site across the country; it is for the local authority to assess whether, in its view, that site constitutes grey be…”
“and learned Gentleman’s point about what is likely to constitute grey-belt land. Let me directly address his other two specific points. Is this a significant policy? Absolutely, and it has been judged as much by the Office for Budget Responsibility and other external commentators. Is it deliberate? Absolutely. We want, as the right hon.”
“Where authorities may wish to restrict development in villages for other reasons, a range of tools are available, such as conservation areas or normal development management policies. On the right hon.”
“We have to put in place policies that, through the decision-making route, allow homes still to be brought forward in that interregnum, but then we have to push heavily to drive towards universal plan coverage. At that point, the protections are in place.”
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“We know these two delivery avenues are important to councils, including those with older homes and those who are looking to rapidly grow their housing portfolios to deal with acute local pressures. We also recognise that certain types of much-needed social and affordable housing can cost more to deliver, including those built by councils. That is why the programme has been designed to be flexible in order to support the greater diversity of supply required, with councils encouraged not to self-censor when coming forward with bids. To improve financial capacity, to deliver new supply and support long-term planning, for the first time, we announced a 10-year social housing rent policy at the spending review.”
“I can confirm that given the priority this Government accord to social rented housing, at least 60% of homes delivered through the programme will be for social rent. Accurately forecasting long-term delivery is inherently challenging—that is one of the reasons we have not set a social affordable housing target to date—but we believe our grant-funded social and affordable homes programme could deliver around 300,000 social and affordable homes over its lifetime, with around 180,000 being for social rent. The programme will continue to support regeneration schemes that provide a net increase in homes. It will also permit a limited number of acquisitions.”
“And we have debated that issue on many, many occasions. I have given the hon. Member very detailed answers as to why, at this point in time, we have not set a target, but we will keep it under review. As I have said, boosting the supply of social and affordable homes is at the heart of our efforts to ramp up housing supply more generally, and because direct delivery by councils has been key to high rates of house building in the past, getting councils building again is an essential part of our strategy. On social and council housing, the Government have put their money where their mouth is. As the hon. Member for North East Hertfordshire made clear, at the spending review we announced £39 billion for a successor to the affordable homes programme over 10 years from 2026-27 to 2035-36.”
“Members in the months to come. Question put and agreed to.”
“Parks and playgrounds provide places for social connection, support health and wellbeing, increase community engagement and volunteering, help people to connect with nature, and can be a foundation for social capital that underpins local opportunity and prosperity. We will continue to do all we can to bring together key stakeholders, as well as local and central Government officials, across the parks and green space sector to identify effective and deliverable solutions to improve the quality and sustainability of those spaces. More widely, this Government remain committed to creating a planning system that delivers the play space opportunities that my hon. Friend’s constituency and other parts of the country need. I look forward in particular to sharing our updated planning policies and designing guidance with him and other hon.”
“Friend mentioned the role of Sport England. With regard to that role, and potentially, as he put it, extending its duties to play, he will know that the Government have a moratorium on new statutory consultees. However, we want to improve and streamline statutory consultee arrangements in England more generally and empower local areas to make those important decisions. We remain committed to ensuring that our playing field capacity is protected and extended, and the NPPF ensures that those interests are maintained in the planning system, as I have set out. Again, I congratulate my hon. Friend the Member for Bournemouth East on securing this debate. I thank him for outlining, with his customary clarity and force, the issues affecting playgrounds in his constituency and around the country.”
“That currently sits within the national planning policy framework, but he knows we are looking at how we make reforms in that area. I have taken on board his points about what more that suite of national policies might do in relation to the provision of play space. I know that he will contribute, as a constituency MP, to that consultation when it goes live. A couple of other points are worth mentioning. The national planning policy framework is supplemented by national design guidance, which encourages the provision of open space and play space, including guidance on types of play space and how this can be integrated into new development in an accessible, inclusive and secure way. We are in the process of updating that suite of national design guidance and we are reviewing existing guidance on play space as part of that effort. My hon.”
“Friend knows—we have had this discussion, and I will continue to engage with him on the subject—that in recognition of the importance of play space provision, we are actively considering what more we can say about this important matter, including on the vital role of communities in ensuring that play spaces are fit for purpose. The debate today has, as have other discussions I have had with my hon. Friend, provided invaluable feedback and experience on play spaces and the issues affecting them in his part of England, and he has spoken about others more generally. We are, as my hon. Friend knows, intending to launch a consultation on what are termed new national policies for decision making—that is, the rules by which development management is managed and taken forward.”
“Information gained from those assessments should be used to determine what recreational provision is needed, which development plans should then seek to accommodate. The framework also includes strong protections for these spaces, where they may be threatened by development. It sets out clear and robust tests that must be met before any development affecting such spaces can be approved. It means that these facilities can be lost only where the facility is no longer needed or where there is a justified and appropriate alternative, such as equivalent or better provision elsewhere. My hon. Friend welcomed the further strengthening of that policy in our update to the NPPF in December last year, through the explicit safeguarding of formal play spaces. My hon.”
“The Government have also committed to simplifying the wider local funding landscape, reducing the number of grants and consolidating them into the local government finance settlement, so that local authorities are able to plan more effectively for infrastructure, amenities and services. As my hon. Friend also knows, because we have had many a discussion on this point, the national planning policy framework includes a number of safeguards for play spaces. It makes it clear that local planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities and opportunities for new provision. That includes places for children’s play, both formal and informal.”
“The boards can choose to use that funding for a wide range of activities, including to upgrade play areas. My hon. Friend knows—we have a difference of opinion on this point—that it is not the Government’s intention to place new statutory responsibilities on local authorities in relation to play. We are instead giving them the freedom and flexibility they need to meet local needs, including looking after treasured green spaces. The spending review provided more than £5 billion of new grant funding over the next three years for local services that communities can rely on. That includes £3.4 billion of new grant funding to be delivered through the local government finance settlement in financial years 2026-27 to 2028-29.”
“We are considering how to bolster further the provision of sufficient opportunities for play, and although I cannot speak for those Departments and their thinking in policy terms, I assure my hon. Friend that the Government as a whole have heard his call to explore a national strategy in the area. With local authorities and industry specialists, the Government have established the parks working group to find solutions to the issues facing parks and green spaces across the country, including in Bournemouth East. The work includes increasing the number of playgrounds more generally. Our £1.5 billion plan for neighbourhoods will deliver funding to enable neighbourhood boards in 75 communities across the country to develop local regeneration plans in conjunction with local authorities.”
“As the Minister for Housing and Planning, I will speak in what remains of my time in large part to the planning system and how it supports play, but I will touch on other areas. Our planning system plays an important role in securing and protecting playgrounds, but this is not the reserve of planning alone. As a whole, the Government are considering how to improve both the availability and quality of play spaces across England. Following my meeting with my hon. Friend after our debate on Report of the Planning and Infrastructure Bill, I wrote, as promised, to my ministerial colleagues in the Department for Education and the Department for Culture, Media and Sport to ensure that we do all we can across Government to support better outcomes for children and communities.”
“I should also welcome him to his role as the chair of the new all-party parliamentary group on play, which, as he mentioned, met for the first time last week. I am delighted that, through that avenue, he will continue to champion this work, and I look forward to the continuing discussions in this area. The Government recognise that access to playgrounds is vital for the health and wellbeing of communities and in supporting physical activity, social cohesion and opportunities for young and old people. My hon. Friend made an important point about the benefits that playgrounds bring for parents and grandparents, who find others in their community to speak to when they are with their children or grandchildren in those settings.”
“It is a pleasure to serve with you in the Chair, Mr Stringer. I congratulate my hon. Friend the Member for Bournemouth East (Tom Hayes) on securing this important debate. I commend him for the eloquence with which he stated his case and how he always speaks on behalf of those he represents. I thank him for the tenacity and dedication with which he has continued since his election to promote playground and play space provision. I note and recognise his ongoing efforts to maintain and improve playground provision in his Bournemouth East seat. His council will have heard that message, too, as it has on other occasions. I thank him for his ongoing engagement with the Department on this matter.”
“Having an up-to-date local plan, or, where one is not in place, ensuring that one is brought forward quickly, is the best way for a community to shape the development required in its area. Where local plans are not up to date or in place, there is a detrimental impact on individuals and communities. We really need to drive that point home: it is not cost-free to not have a local plan in place.”
“Friend will appreciate that I am unable to comment on individual local development plans or individual planning applications in her constituency due to the role of Housing, Communities and Local Government Ministers in the planning system, but I will seek to respond to as many of the general points that she raised as I can. If there are any that I am unable to cover in the time that I have, I will happily write to her with further detail. I very much welcome the fact that the local planning authorities that cover parts of my hon. Friend’s constituency are all taking forward draft local plans. It is really important that local plans are put in place, and at speed.”
“It is a pleasure to serve with you in the Chair, Ms McVey. I congratulate my hon. Friend the Member for Stoke-on-Trent South (Dr Gardner) on securing the debate and commend her for managing to fit a phenomenal number of issues into that very brief speech. In general terms, I can assure my hon. Friend that the Government want to see more plan-led development and want development generally to provide all the infrastructure, amenities and services necessary to sustain thriving communities. While there is much more to be done, I trust that she recognises that the Government have already taken decisive steps to deliver on those objectives. My hon.”
“Friend the Member for Stoke-on-Trent South mentioned a number of issues in relation to brownfield development—development on previously developed land—as well as green-belt development. It should be said at the outset that, like all Governments over the last few decades, this Government have a brownfield-first approach to development. We want, in all cases, local authorities to exhaust their options for brownfield development. Indeed, we are making that easier: we made changes to the NPPF in December, and we have consulted on what we call a brownfield passport—essentially a means of making sure that, when applications on brownfield land are suitable, the default answer should be a straightforward yes.”
“It is right that, in those circumstances, development comes forward outside of plans—the homes our country needs cannot be put on hold—but we have made it clear that that is not a route to poor-quality housing, and we have added new safeguards to the presumption in the national planning policy framework in order to ensure that. It must also be said that the absence of an up-to-date local plan does not remove the need for local planning authorities to consider the use of conditions or planning obligations to make otherwise unacceptable developments acceptable. That can include the provision of necessary site-specific infrastructure at appropriate trigger points in development. Local planning authorities already have enforcement powers to ensure compliance with such provisions. My hon.”
“We are also introducing a faster and clearer process for preparing local plans, which will set a clear expectation that local plans—as well as minerals and waste plans, it should be said—should be routinely prepared and adopted within 30 months. Other aspects of the reforms—such as the introduction of gateways; shorter, simpler and standardised content focused on the core principles of plan making; and a series of digital transformation initiatives—will support that aim. I very much commend the efforts being made in the area in question to get the local plan in place. As I said, where local plans are not up to date, and where LPAs are not delivering in line with the needs of their communities, areas are open to speculative development.”
“I thank my hon. Friend for that intervention. I am more than happy to pick up that conversation and see where we have got to. For the reasons I have already given, I will not be able to comment on the local plan in question, but suffice it to say that we have a local plan-led planning system, and such a system operates effectively only if coverage of up-to-date local plans is extensive. My hon. Friends will no doubt be aware that the Government inherited a system in which less than a third of local plans were up to date. We have taken decisive steps to progress towards our ambition of universal local plan coverage, both by providing local planning authorities that are striving to do the right thing with financial support and by intervening where necessary to drive local plans to adoption as quickly as possible.”
“National policy makes it clear that, in those circumstances, local development plans must take a sequential approach: first exhaust previously developed land, then consider low-quality grey-belt land that is not previously developed, and only then consider other green-belt locations. Under our revised approach, the sustainability of green-belt sites must also be prioritised, and local planning authorities must pay particular attention to transport connections when considering whether grey belt is sustainably located.”
“In those instances, we expect it first to demonstrate that it has examined fully all other reasonable options for meeting identified need for development, including making as much use as possible of suitable brownfield sites and underutilised land, optimising the density of development—a number of local authorities across the country are looking again at brownfield sites and exploring whether they can get additional density to make up housing numbers—and working with neighbouring authorities to assess whether identified need might be sensibly accommodated across borough boundaries. Where those options have been exhausted, we expect local authorities to look again at green-belt land release.”
“We have acted quickly to replace the haphazard approach taken by the previous Government to green-belt designation and release with a more strategic and targeted approach. I emphasise that Ministers do not themselves determine what, if any, grey-belt land is released in any given local planning authority area. It is for the local planning authority itself to determine whether exceptional circumstances exist that justify doing so.”
“I will happily take that conversation up with colleagues in other Departments, and I am happy to write to my hon. Friend about heritage policy in the planning system more generally if he would find that useful. The point needs to be made, and it needs to be made again and again, that there is not enough brownfield land on registers—and certainly not enough viable sites in the right locations—to meet the demand for homes across the country. That is why we have taken a different approach to the green belt. We are committed to preserving green belts, which have served England’s towns and cities well over recent decades, not least in checking the unrestricted sprawl of large built-up areas and preventing neighbourhoods from merging into one another.”
“I am looking forward to that meeting. The relevant diary slots have moved around on several occasions, but I will ensure that it takes place in the very near future. We can discuss that and other issues. Because we recognise the value that communities place on green-belt land, we have taken steps to ensure that any necessary development on it must deliver high levels of affordable housing; the provision of new green spaces, or improvements to existing green spaces, that are accessible to the public; and necessary improvements to local or national infrastructure. Our new golden rules, which are the mechanism by which we will deliver that public gain, will apply where a major housing development is proposed on green-belt land, released either through plan making or subject to a planning application.”
“If they get those things—this will not be the case for all her constituents, as it is not the case for all of mine, but it will be true in lots of cases—and we ensure that we get better development as well as more development, that will be a way to assuage some of the concerns that communities have about what housebuilding in their area means. I look forward to continuing to engage with her to ensure that the changes the Government have already made, along with those to come, of which there are many, are of lasting benefit to her constituents as well to as others in the region. Question put and agreed to.”
“I am more than happy to pick up conversations, and to meet them as a group rather than individually if that is useful, since some common concerns have been raised. I thank my hon. Friend for the clarity with which she expressed the concerns of her constituents and the points that she made. I emphasise once again that the Government are in complete agreement with my hon. Friend on the importance of plan-led development that provides the necessary infrastructure, amenities and services that communities want.”
“As I said, we will bring forward further reforms to strengthen the section 106 system so that councils are better placed to strike those agreements and ensure that developers are held to the commitments they make. My hon. Friend raised a number of other issues, including empty homes. I am more than happy to write to her on them. Community right to buy is not my responsibility as a Minister, but I will get the appropriate Minister in my Department to provide her with an update. She rightly mentioned the provisions in the English Devolution and Community Empowerment Bill, which recently had its Second Reading. I commend my hon. Friend for securing this debate and other hon. Members for taking part. There is clearly a shared set of issues among a set of colleagues that needs addressing.”
“Any local planning authority that receives a contribution from development through section 106 planning obligations must prepare and publish an infrastructure funding statement at least annually. Reporting on developer contributions helps local communities and developers see how contributions have been spent—and, in some circumstances, underspent—and what future funds will be spent on, ensuring a transparent and accountable system. I know from my own constituency, and I hear from many hon. Members, that what communities want is transparency about where those funds go and certainty that they are being spent on the right mitigations to ensure that development is made acceptable.”
“While there is a variety of entirely legitimate reasons why local planning authorities may be holding unspent developer contributions, including to facilitate the effective delivery of phased development projects, we recognise the need to ensure that the contributions that developers make to mitigate the impact of development and make it acceptable in planning terms are used effectively and in a timely manner. Local planning authorities are expected to use all the funding received by way of planning obligations. Individual agreements should normally include clauses stating when and how the funds will be used and allow for their return after an agreed period of time where they are not. The planning advisory service, funded by my Department, provides support to local planning authorities in the governance of developer contributions.”
“However, the chief planner has written to local planning authorities to remind them of their statutory duty to prepare and publish an infrastructure funding statement where they receive developer contributions via section 106 or community infrastructure levy. As my hon. Friend the Member for Stoke-on-Trent South knows, the Government also provide financial support for essential infrastructure in areas of greatest housing demand through land and infrastructure funding programmes, such as the housing infrastructure fund. The Government are also committed to strengthening the existing system of developer contributions to ensure that new developments provide necessary affordable homes and infrastructure. We will set out further details on that specific point in due course. My hon. Friend mentioned the issue of section 106 moneys.”
“The provision of infrastructure is incredibly important. The NPPF sets out that the purpose of the planning system is to contribute to the achievement of sustainable development, including the provision of supporting infrastructure in a sustainable manner. The revised NPPF we published last year also supports the increased provision and modernisation of various types of public infrastructure. Planning practice guidance recommends that, when preparing a local plan, local planning authorities use available evidence of infrastructure requirements to prepare what is known as an infrastructure funding statement. Such statements can be used to demonstrate the delivery of infrastructure through the plan period. There is already detailed guidance and an infrastructure funding statement template on the planning advisory service website.”
“It is probably worth me writing to my hon. Friend. The Government have undertaken a number of reforms—building, it has to be said, on reforms made by the previous Government in the last Parliament—to compulsory purchase powers. Some of those powers are novel; not many places, if any, have tried some of the new powers that I have brought into force. We are very encouraging of any local authorities that want to explore them. Let me set them out in writing to my hon. Friend so that he has the full detail. In the time left, I want to address a couple of other issues that were raised, starting with infrastructure provision. As my hon. Friend the Member for Stoke-on-Trent South made clear, communities across the country want to see infrastructure delivered as early in the development process as possible rather than as an afterthought.”
“As hon. Members will be aware, the Bill as originally introduced, mirroring provisions in the previous Government’s Renters (Reform) Bill, enabled landlords to request such insurance in instances where a tenant had requested a pet. In response to concerns expressed by several peers that the insurance industry appears unlikely to provide suitable financial products at the speed and scale required, and that the reasonable request of tenants to keep pets might be hampered as a result, Lords amendments 10, 12 and 13 remove the provisions in the Bill which made landlord consent to a request to keep a pet conditional on the tenant taking out, or paying for, pet damage insurance.”
“I want to reiterate what Baroness Taylor made clear in the other place—namely, that it is not the Government’s intention to make use of this new power unless and until it is considered necessary to avoid lengthy delays for genuine cases to be heard. If used, it would be subject to the affirmative procedure to allow appropriate parliamentary scrutiny. In addition to introducing that important safeguard, the Government also concluded that there is a compelling case for the use of an alternative body or mechanism to make initial rent determinations. Subject to a final viability assessment, we intend to establish such an alternative body or mechanism as soon as possible, and will confirm further details in due course. The second important change the Government made in the other place concerns insurance to cover potential damage from pets.”
“It is essential that we deliver on that commitment not only to protect tenants from undue financial pressure, but to prevent rent hikes from being used as a form of back-door eviction once section 21 notices have been abolished. However, recognising that there is inherent uncertainty about the volume of rent increase challenges that will be brought when the new tenancy system comes into force, and as a safeguard against a scenario in which the first-tier tribunal is overwhelmed by a sharp increase in challenges, Lords amendments 6 to 8 introduce a new delegated power that will enable the backdating of rent increases following determinations by the tribunal of new rent amounts.”
“As you will know, Madam Deputy Speaker, the Government made several important changes to the Bill in the other place with a view to ensuring that it will work as intended and in response to the legitimate concerns raised about the implementation of specific provisions. In the interests of time, I will update the House only on the two that are most apposite. The first change concerns the date from which a tenant is required to pay a new rent in instances where the first-tier tribunal has set a new rent amount following a tenant’s challenge to a proposed increase. The Government were elected on a clear manifesto commitment to empower tenants to challenge unreasonable rent increases.”
“This Government were elected with a clear mandate to do what the Conservatives failed to do in the last Parliament—namely, to modernise the regulation of our country’s insecure and unjust private rented sector, and empower private renters by providing them with greater security rights and protections. Our Renters’ Rights Bill does just that, and it needs to receive Royal Assent as quickly as possible so that England’s 11 million private renters can benefit from its provisions. Before I turn to the Lords amendments, I want to thank Baroness Taylor for so ably guiding the Bill through the other place. I put on record my appreciation of all the peers who contributed to its detailed scrutiny.”
“I want to make it clear that the Government recognise the plight of shared owners living in buildings that require remediation. I know from my own efforts to support shared owners in my constituency of Greenwich and Woolwich that those affected by the building safety crisis often face unaffordable costs, often with no viable exit route other than a distressed sale.”
“We recognise that there will be occasions when landlords regain vacant possession of their property using ground 1A but are unable subsequently to sell it despite repeated attempts to do so, but we are not prepared to weaken the strong safeguard against abuse provided by the 12-month no-let provision. It is essential to prevent landlords misusing ground 1A and evicting tenants who are not at fault, whether that be because they have made a legitimate complaint or simply because the landlord wants to re-let at a higher rate. The Government remain firmly committed to the 12-month no-let restriction, and I urge the House to reject Lords amendment 18 on that basis. Lords amendment 19 is a related amendment that exempts shared owners from the 12-month re-letting and re-marketing restriction, as well as other important restrictions.”
“First, while I appreciate entirely that some peers currently own and let rental properties in close proximity to their homes, with a view to one day using them to house a carer for themselves or members of their family, there is no compelling evidence to suggest that this practice is sufficiently widespread to justify the insertion into the Bill at this late stage of a dedicated possession ground to cater specifically for it. Secondly, the definition of “carer” in the amendment—namely, anyone providing any form of care in a voluntary or contractual arrangement, is so broad that the scope for abuse, in our view, is substantial. I therefore urge the House to reject the amendment. Lords amendment 18 would reduce the prohibition on re-letting or re-marketing a property following the use of possession ground 1A from 12 months to six.”
“We believe restricting its use to HMOs or dwelling-houses in HMOs strikes the right balance, and I therefore urge the House to reject Lords amendment 53. Lords amendment 64 introduces a new ground for possession for the sole purpose of allowing a landlord to regain their property to house a carer for themselves or a member of their family living with them. Everyone in this Chamber recognises the vital work carers do to support people to live independently and with dignity. However, while the Government are profoundly sympathetic to the needs of those who require care, I am afraid we cannot support this amendment for two main reasons.”
“Let me make clear precisely, in each instance, where that is the case, starting with Lords amendment 53. Lords amendment 53 dramatically broadens the scope of possession ground 4A, so that it encompasses not only full-time students living in houses in multiple occupation, but non-typical students, such as older students with families undertaking postgraduate studies who may live in self-contained one and two-bed properties. Ground 4A exists precisely because the Government recognise the unique nature of the student rental market and are determined to ensure that the annual cycle of student lettings continues accordingly. However, ground 4A was deliberately designed to ensure that the benefits of the new tenancy system introduced in the Bill were not denied to non-typical students.”
“As ever, I thank the hon. Gentleman for his intervention. He makes a good point. There is evidence that pet damage is, in many cases, not extensive or a particular issue. Where pet damage occurs, as I will come on to make clear in response to the relevant Lords amendment, we think that the provisions in the Tenant Fees Act 2019, which allow for tenant deposits to be changed in response to such issues, mean that we have the necessary delegated powers, but I will set out further detail on that particular issue in due course. I will now turn to the amendments made by peers in the other place. We welcome the scrutiny and challenge provided, and are willing to make sensible concessions in some areas, but most of the amendments in question serve to undermine the core principles of the Bill and for that reason we cannot accept them.”
“The shadow Secretary of State failed to address the second concern the Government have about amendment 21, which is the substantial risk of abuse that will flow from the definition of a “carer”. The definition under the amendment could be anyone providing any form of voluntary care. It could be someone who provides the weekly shop. Does he not see the risk of abuse that comes with a ground that is so broadly drawn? That was our other concern, and he has not addressed it.”
“Do those on the Lib Dem Benches have any concerns about one of the issues that I raised: applying the decent homes standard to the defence estate in England when a different standard will apply to Scotland and Wales—to other parts of the United Kingdom? Fracturing the defence estate in that way is problematic.”
“I urge the hon. Gentleman to engage with the clear concession I made from the Dispatch Box: the confirmation that the Ministry of Defence will lay before Parliament—and publish on gov.uk—an annual report on the standard of service family accommodation in the UK, giving transparency, accountability, and reassurance that the standards we all want to see improve and be met will be.”
“I have offered a very clear concession from the Dispatch Box that we will provide for annual reporting to give the transparency and accountability that those standards will be met.”