owners of small domestic buildings which are important to the loca1 scene out in:, the cold; al though it may well prevent unnecessary applications designed mainly to collect the grant regardless of the effect on the building. Also, moving away from relating the grant to the building alone is the perennial problem of all officers administering grant, and one which is not easily resolved. When should help be given (para.29), and .:..n what form? The proposal is to offer mandatory grant aid to any dwelling below the proposed new standard of fitness (see later notes). ACO feels that the emphasis here should be on the provision of a bathroom, kitchen, roof repairs and curing damp. The mandatory grant will only be offered to houses declared unfit. Discretionary grants such as improvement and repair grants have caused confusion, and will now be phased out to be replaced by a loan system, which will apply to all properties pre-1940 (not pre-1919 as previously). The loans are to be assessed as a percentage of the valuation of the property when work is complete, for purposes of re-payment. This means that if the house continues to increase in value,.more is re-payable than originally borrowed. Many owners will feel this to be a positive disincentive to seeking grant aid. The loan will be registered as a land charge, but will not be contributed to by the government. This is a major flaw, as in the early years local authorities will need an injection of capital. The local authority can vet builders, and only builders whose estimate is accepted can be used. The eligible expense limits are tied to the income level of the applicant, and care would need to be taken to see that this was not detrimental to listed buildings. Grant aid to developers (para 47) Grants would be given when the proceeds from sale are insufficient on their Page 7 own to provide an adequate financial return. Area Improvement policy (para 49) The main purpose of designating areas for improvement would be to attract funding from private sources. A single type is proposed -the Housing Improvment Area, and grant aid would pe available for a total of seven years to cure social problems by solving housing problems. Again, the emphahsis would appear to be away from the houses themselves, and throughout the paper there is no mention of retention of character. The paper could be more enthusiastic about enveloping and block repair of properties. Although this is no longer going to be limited ~o improvement areas, and there is going to be legislation to enable local authorities to carry out such work, owners will now have to contribute 10% of the cost for their individual property, except in cases of extreme hardship. ACO feels that there should be more emphasis on enveloping in the whole sphere of improvement and repair grants. The biggest single problem; particularly in urban~areas, is the need for roof repair .. It forms a very high percentage of applications for Town Scheme grant, and if Housing Act grant was directed towards the problem, then it would leave conservation grants greate~ scope for other important conservation work. Standards of fitness (para 61) There is to be a new 'tolerable standard' which in reality is very similar to the old, but a house only falls below standard if it fails to meet the requirements in one or more respects. No overall judgement is required. This may help to obviate the making of many unnecessary demolition and closing orders. The good news is that it no longer requires 'internal re-arrangement' - so the plan form of a building, so important for understanding its plan form and social status, may now stand some chance of staying intact. The
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