Salford Citizens Advice

Council Tax Local Scheme Proposals Consultation:

Thank you for the opportunity to comment on the proposed new local council tax scheme. We are pleased to make the following comments.

We appreciate the difficult position the local authority faces in bringing forward a local council tax benefit scheme, and doing so within the context of nationally reduced budgets.

We believe that improved strategies around debt recovery and more effective uptake of council tax support could mitigate the effects of reduced national funding for the new scheme.

Last year Salford Citizens Advice provided advice to over 18,000 Salford Citizens. Specifically we gave advice on council tax benefit and council tax arrears to 1700 people and 12% of our debt enquiries are around arrears of council tax payments.

We are concerned that the reduction of our funding over the last two years has prevented us from providing interventions with clients that enabled them to resume council tax payments. Specifically for every £1 the city council invests in our service there is an extra £19 of council tax recovered.

We think the council needs to acknowledge that plans to improve  recovery  of unpaid council tax must form part of the scheme proposals  and that these should include better partnership working with advice agencies in the city.

We recommend that the City Council looks to ensure that it follows the arrears good practice protocol, as established with the Local Government Association.[1] We think that with the inclusion of significant number of low income households into the need to pay council tax for the first time, it is likely that there will be significant additional pressures on the council’s recovery rate; making this a key time to review these matters.

All council tax support will be calculated on a band charge for a band A property (1a.)

We are concerned that this proposal will have a disproportionate impact on people with disabilities. These may well lose the benefit of being able to apply for a council tax rebranding where they live in properties banded B or above, and have made adaptions to their property to allow them to continue to occupy their property. We think your proposals should ensure that people facing the additional costs of disability adaption to properties should be better protected. We are also concerned that this proposal would have a disproportionate impact on low income households.

That all council tax support would be calculated to a minimum of 85% and 90% of band A:

 We are concerned that this is not clear enough for people to be able to comment on your proposals. We are also concerned that in future it lacks transparency.

We would limit council tax support to 91.5% of their council tax bill for everyone of working age:

 We think this addresses some of our concerns raised in our answer to your proposal 1a. We favour option 1b over 1a.

Second adult rebate be withdrawn for people of a working age:

 On balance we welcome this simplification of the council tax benefit scheme; although we note that the protection will still apply to non-working age people.

We would recommend that a more detailed proposal to provide transitional relief to people affected by this measure be brought forward.

Benefits will not be paid where the weekly support is less than £1.00:

 We have no comment to make.

Additional support for people in extreme hardship:

 We welcome increased support for people in special hardship. This said, we are concerned with the general move from a rights based benefit scheme to one with greater levels of discretionary decision making. We think this is less easy for people to understand and plan around. We think it gives rise to the risk of further expense in handling claims, and any appeals against decisions. We also note that discretionary hardship budgets are often under spend, leaving less resource for people in need. It is difficult for us to comment further because of the lack of detail in your proposals around this point.

We would increase the ‘taper’ applied to calculate council tax support for people of a working age from 20% to 25%:

 We have no comment to make.

We would increase non-dependant deductions for working age households:

 We in general feel that the use of non-dependent deductions in both the housing benefit and council tax benefit system creates significant difficulties for many people. We know that is a major cause of arrears. We note that over the last years non-dependent deductions have increased disproportionately.

We would not accept any backdated tax support claims for working age people:

 We are concerned that this proposal is too inflexible. We think it will disproportionally impact on those clients with communication needs either through disability or skills. We think this proposal is likely to have a disproportionate adverse equalities impact. We would like to see the council’s equalities impact assessment for this proposal.


Tom Togher

Chief Officer

Salford Citizens Advice.