Only a few days to go: We’re raising £25,000 to keep TheyWorkForYou running and make sure people across the UK can hold their elected representatives to account.Donate to our crowdfunder
The following Statement was made on Wednesday 13 May in the House of Commons.
“Moving home can be a life-changing moment for many among us. For young families spreading their wings after a new arrival, for young people leaving their parents’ home for the first time, or for working people changing towns or cities to start a new job, moving home means planting your roots; laying your foundations. A home is more than four walls and a roof—it is a sanctuary, a form of protection, and a link to your community.
We know that people’s homes are at the heart of their own personal stories, and throughout the course of this emergency, we have, by necessity, put many of those stories on hold, to protect our communities and to save lives. When the essential ‘Stay at home’ message was announced, we changed the rules so that people could move home only if they thought it was ‘reasonably necessary’. For many people, this has put life on hold, with this most relevant and essential industry in a state of suspended animation. Over 450,000 sales have been stuck in the system, unable to be progressed—not to mention the substantial number of rentals that have not gone ahead. Every month, 300,000 tenancies come up for renewal, a proportion of which result in people moving home. The pressure to move has, for some, become acute, with profound legal, financial and health implications.
We made that decision in order to keep the country safe, but as we move into the next phase of our Covid response and embark on our path to reopen, restart and renew the economy, we recognise the need to let people get back to living their lives. That is why today I am announcing a comprehensive, clear and coherent plan to reopen the housing market and to restart the construction industry. With immediate effect, we are lifting the temporary freeze on moving home, meaning that, as long as they are not shielding or self-isolating, anyone can move, any time and for any reason.
The industry is broad, and has many moving parts, so we want to be clear: each of the building blocks of the buying and selling process are now back in business, as long as it can be done safely. Here, then, is our plan for the reopening, restarting, and renewing of the housing market and the construction industry: estate agent offices can now reopen, removal companies can get moving again, surveyors, conveyancers and valuers can go back to work, and show homes on sites can reopen.
It is crucial that these changes happen safely and that we continue to tread with caution, to control the virus and to protect the public. This means that as these businesses reopen they will need to adapt their practices; for instance, with virtual viewings where possible and cleaning thoroughly after viewings and when moving. I have published detailed guidance, informed by public health advice, to explain how this can be achieved, building on the existing safer working guidance, with all parties observing hygiene measures and social distancing guidelines.
For each of the other elements that make up the wider construction industry—a sector that employs more than 2 million people—the same applies. If people are self-isolating or have coronavirus, they should of course not be moving or going back to work. All parties involved in home buying and selling should prioritise agreeing amicable arrangements to change moving dates for individuals in this group.
This is the most radical restarting of an industry in the first phase of our national recovery road map. It was not an easy decision to make. With few, if any, transactions, there is no visibility and no precedent with which to accurately judge the state of the housing market, but I do know that in every economic recovery in modern British history the housing market has been key, so let me be clear to all who work in the sector, have started a business in it, have invested in it, or rely upon it: I am doing everything I can to help the industry bounce back.
A healthy housing market means more than buying and selling houses; it requires building them too, but Covid-19 has had a profound impact on housebuilding, with activity on sites down by around 90% since this time last year. I am delighted to see so many construction companies back at work already, and I am pleased to be supporting their efforts by today announcing the launch of a safe working charter with the Home Builders Federation. Those working on site should feel confident that their essential jobs are also safe jobs.
I am taking further steps to support safe housebuilding by allowing more flexible working hours on construction sites, where appropriate and with local checks and balances. I am allowing sites to apply to extend their working hours, again with immediate effect. Varied start and finish times will make it easier for sites to observe social distancing, will take pressure off public transport, particularly in our core cities, and will keep Britain building.
The planning system, too, must be able to operate safely and efficiently during this time, which means, as with many other sectors, making more use of digital technology. I want the Planning Inspectorate to be at the forefront of this work—it is good to see the inspectorate now undertaking its first virtual hearings. I am asking it to make all hearings virtual within weeks. We are going to get the planning system going again and bring it into the digital age at the same time.
As we look to the future, we must remember that the prospects for Britain’s housing market are key to our economy: when this sector succeeds, we all succeed. This is what shapes our vision for the housing market: more homes, safer homes, homes of higher quality, more beautiful homes, homes of all types and tenures, for all people, rooted in and at the heart of their communities. Today, we reopen, restart and renew the housing market and the construction industry to protect lives, save jobs and refresh and renew our economy.”
The Statement was considered in a Virtual Proceeding via video call.
My Lords, I declare my interests as a vice-president of the Local Government Association and as a trustee of the United St Saviour’s Charity, which owns two almshouses for the benefit of Southwark residents.
I pay tribute to everyone in the public and private sectors who is working to keep us safe, delivering our essential services and ensuring that our shops are stocked with food so that together we can get through this crisis. These are the real heroes of the crisis, and they come from all over the globe. Everyone deserves to live in a home that is warm, safe and dry.
I am supportive of the Statement but with the underpinning that keeping people safe must be paramount in the thinking as we move to this next phase of fighting the pandemic. There are great risks and we do not want to do anything that risks a second spike in infections.
Of course, there is much that is not in this Statement, so my first question for the Minister is: can we expect further updates from his department on other aspects of housing in the next few days? Furthermore, can the Minister tell the House what the next phase of fighting this pandemic will look like for homeless people? Will he take this opportunity to confirm that they will not be sent back on to the streets? What discussions have taken place with the Local Government Association and Crisis on this next phase of the pandemic battle for homeless people?
In respect of viewings of properties for sale or rent, what review mechanism will the Minister deploy and how long after the physical viewings are in progress will he deploy it—one month, two months, three months? What discussions have taken place between him or his officials and the Residential Landlords Association, the Association of Residential Letting Agents, the National Association of Estate Agents, Generation Rent and Shelter, among others, on the resumption of viewings and lettings and the safety both of those coming to visit and of those whose properties are being visited?
The ban on evictions has been most welcome, and the Government deserve credit for that. It was the right thing to do. However, at some point this ban will be lifted, either in June or at some future date if the ban is extended. Can the Minister tell the House what thinking is taking place in the department to avoid a large number of evictions being progressed? We cannot have this situation in future.
Where home sales or lettings go through, we will have people moving home and in many cases using the services of a professional removal company. Has there been any discussion with the British Association of Removers? In any industry, but particularly the removal industry, social distancing can be quite difficult to achieve. We need to be clear on the correct practice when people move home.
I am conscious that I have asked a number of questions. I hope that I will get full answers but accept that that might not be possible tonight. Brief comments would be helpful for all Members, but if the Minister would agree to follow up any comments he makes on the points I have made with a letter to all Members and to place it in the Library of the House, that would be very helpful.
My Lords, I thank the Minister for taking questions on this Statement made by the Secretary of State last Wednesday on the restarting of the construction industry. It came as a surprise to many in that sector, given that they have continued to work throughout the lockdown. In the week before the Secretary of State’s announcement, only 37% of sites remained closed. For the smaller businesses that have been closed, this is often due to supply chain issues alone.
Given how keen the Government are to get all construction back to peak levels, can the Minister reassure us that safety in that sector is as important as in any other? What steps are being taken to ensure that low-skill workers in construction are safe and social distancing? The latest ONS figures suggest that construction worker death rates from coronavirus are double those of health workers. You have only to take your daily exercise past most building sites to see a frightening absence of social distancing. When the Minister answered a question from my noble friend Lord Stunell on
Can the Government reassure us that all types of tenure are equal? With this Government it sometimes appears that some types of tenure are more equal than others. The Housing Secretary’s Statement talks at length about the importance of a home, but the only policies available are for owner-occupiers. People who rent need to know that their home is secure and safe. They need that assurance now. Will the Government agree to extend the current change on Section 21 evictions to give renters the security they need over a long-term period in advance of the
Is the Minister aware of Shelter projections that there will be a £55 million a month gap in rent without additional government support because universal credit is too low to cover average local rents? Does the Minister accept that the greatest danger for people on low incomes is that their rent arrears will accrue, driving them into a level of debt from which it would be hard to recover? Will the Government perhaps learn from other European nations and offer low-interest loans to help tenants through this unprecedented period?
The problems of leaseholders with extortionate ground rents have not suddenly disappeared with the lockdown. What progress is there in tackling this? Where are the shelved plans for greater protections for property guardians who are struggling to socially distance in often inadequate accommodation?
The achievement of getting as many rough sleepers as possible sheltered during this period is very significant. Anyone who has had the privilege of working with Dame Louise Casey will know how able she is at making the impossible possible, but this was also achieved thanks to monumental efforts by local authorities. Those same local authorities now need support to build social housing in sufficient numbers. Will the Minister listen to the LGA when it asks the Government to allow councils at least five years to spend right-to-buy receipts? Will they also allow councils to keep 100% of receipts?
Will the Government increase investment in Housing First projects to ensure that we do not return to the shameful levels of rough sleeping before the pandemic? Will the Government also support local authorities in their attempts to house people who have no recourse to public funds? This global problem requires a global response. Last week, the Secretary of State left responsibility for this issue firmly in the hands of local authorities. He charged them to act with humanity and compassion. Does the Minister agree that the Government should do the same?
A number of questions have been put; where I do not know the answer, I shall write to the noble Baroness or the noble Lord and place a copy of my response in the Library.
I shall start with the questions put by the noble Lord, Lord Kennedy. A ban on evictions is in place, which we shall review in due course once it is released. We have engaged with a number of stakeholders regarding rough sleeping. It is incredible that 90% of rough sleepers—some 5,400 people—have been taken off the streets. Engagement is happening with local authorities, charities and, as I know, the Local Government Association, to come up with a big, bold plan to ensure that these people remain in secure and settled accommodation and do not just get handed back on to the streets.
The noble Baroness mentioned being able to resume construction safely. I note the ONS figures. We know that guidance has been issued on how to restart safely, including a charter on construction safety. Over 100 construction companies have signed that charter and we look to more to do the same. Obviously, the raised levels among construction workers are not necessarily down to construction; there could be other factors such as underlying conditions. We will continue to monitor that.
We assume that access to PPE should be no problem with routine construction. Construction workers have access to testing, as do other key workers, as we reopen the economy. I note the comments around low-interest rates to tenants. I shall write specifically on that to the noble Baroness. We need to recognise that restarting construction is a key part of reopening our economy. The Government recognise that between 600,000 and 900,000 people are employed in the housing sector alone and many millions in the wider construction sector; but we understand the need to do this safely.
We now come to the 30 minutes allocated for Back-Bench questions. I ask that the questions and answers be brief so that I can call the maximum number of speakers.
My Lords, I welcome my noble friend to his position and thank him for taking questions. He will realise that many of those who suffered in the winter floods are still being rehoused. Does he have any idea how many are in that position? Will he take this opportunity to pause before any new houses and major developments are completed to make sure that our future housing stock is resilient, especially to floods? Will he give an undertaking that the Government will stop allowing developments in inappropriate places such as functional flood plains and ensure that there are adequate drainage systems to prevent overflows from combined sewers?
I declare my interests as per the register. The MHCLG said that smaller property developers would be able to defer payments to local councils in a bid to stop them going to the wall. What do the Government intend to do to stop councils going to the wall? The County Councils Network has called for a £5 billion income guarantee from government to help councils make it through this crisis period. Local authorities are at risk of having to declare insolvency as the pandemic continues. There is currently a £10 billion gap in council funding in England. At this rate, there may not be council planning departments in existence for property developers to request deferment of payment from.
The information that we have in the department is that no Section 114 notices are imminent. We need to recognise that this Government have provided around £20 billion of investment into local services in just two months. That includes two tranches of £1.6 billion to ease demand pressures on local councils and around £5 billion of cash-flow measures, as well as other measures to support wider transport issues, including the recent bailout of Transport for London. I note the noble Baroness’s concerns, but at the moment we have no evidence that councils are about to go to the wall.
My Lords, the Minister will have noted the predictions of property economists that prices of land and property could fall by 10% to 30% in the year ahead. Does he agree that, rather than see speculators and foreign investors snapping up stalled developments and cheaper sites and properties, this is the moment for government to back social housing providers to buy and to build to achieve the 100,000 homes a year so badly needed by those who cannot buy and who struggle with private sector rents? That includes the essential workers, nurses, social workers and bus drivers on whom we now utterly depend but whose housing needs we have so neglected.
The noble Lord is right that we must ensure that we have housing of all types and tenures, including affordable housing for key workers, as he outlined. I note that the affordable homes programme for the next five years is £12.5 billion—that is greater than the amount for the previous programme of £9 billion. We should ensure that building of more affordable housing can begin and that such housing is not for people who have not made their contribution to this country. There are ways of ensuring that we do that. I thank the noble Lord for his question.
My Lords, the Statement speaks of homes for all people as the Government’s vision, so I congratulate them on the funding they have made available which has allowed a huge amount to be done to support homeless people in a very short space of time. Does the Minister accept that withdrawing dedicated funding risks undermining all that has been achieved in providing housing as a first step towards the homeless having homes?
My Lords, in its current form, the Help to Buy scheme will expire in 2021. It is due to be replaced by a new scheme, which will run from 2021 to 2023 and will contain certain restrictions. If the original scheme comes to an end as planned, qualifying sales will need to be agreed by December 2020. In view of the pandemic, we should perhaps consider extending the current scheme. Can my noble friend the Minister say whether this could be considered?
My Lords, the Statement describes the situation prior to the easing it contains. It states that life has been put on hold and that 450,000 sales have been unable to be progressed. Rentals are not going ahead and 300,000 tenants are waiting for their renewals. It says that the pressure on some people has,
“become acute with profound legal, financial and health implications.”
I understand that the changes proposed in the Statement do not apply to those who are shielded under the current arrangements. Can the Minister confirm whether that is right and can he say what might be done to give some sort of equivalence to those who are shielding who could otherwise miss out but who are facing the same challenges as others?
I understand that the proposals do extend to the vulnerable, but it is their decision as to whether they go ahead. However, I will write to the noble Lord and place a copy of my specific answer in the Library.
The noble Baroness, Lady Grender, referred to the tragic death toll from Covid-19 among construction workers. Does the Minister agree that that is just one sign of a deeply unhealthy industry that is built quite literally on the backs of the 60% of manual construction workers who are in self-employment, very often bogus self-employment, where they are actually working for just one company under its direction and with dictated rates of pay? Will the Government look to build a different kind of construction sector, one that focuses on decent pay and conditions and that looks towards moving towards modern, modular construction whereby most of the work can be done in factories and therefore in far better conditions than being out in all weathers?
We need to ensure that construction happens safely. That is why we have engaged with the Construction Leadership Council which has issued guidance on safe construction. We also work with the Home Builders Federation. It is important to ensure that the guidance is followed and we are encouraging the whole construction industry to sign up to the guidance that has been issued by the HBF.
My Lords, I declare an interest as chair of the Cambridgeshire Development Forum and I welcome my noble friend to his ministerial position. Will the Government introduce primary legislation to give a general power to local authorities so that they will be able to extend planning permissions that are currently in force, taking into account the disruption to construction and development activity?
The Government are aware, from both local planning authorities and the development industry, that there are delays caused by the Covid-19 pandemic. There is a risk of unimplemented planning permissions collapsing and therefore undermining the delivery of projects. We recognise these concerns and are considering whether permissions should be extended.
My Lords, while the Government’s intention to restart the housing market is welcome, provided that it is done under safe conditions, are the Government considering the following: backing local authority recovery plans through a combination of accelerated capital investment and low-cost lending in housing to get the sector moving again; protecting and accelerating council housing programmes under which thousands of homes are planned across the country, focusing on social and affordable rental homes; bringing forward future phases of development on largely privately owned sites through a combination of grants and guarantees, backed by central government, and conversion to affordable and key worker housing and build to rent; and, finally, creating a programme of specialist housing delivery, to keep rough sleepers off the streets for ever?
That is a many-pronged question, if I may say so. On the last point, having taken 5,400 people—over 90% of rough sleepers—off the streets, we have a great opportunity to work on a big, bold plan to ensure that those people stay in settled and secure accommodation. Louise Casey is working with officials, local authorities and homelessness charities—this involves all layers of government—to develop the necessary measures to achieve just that. It is a once-in-a-generation opportunity. The noble Baroness raised other technical points; I will write to her on those and place a copy in the Library.
I declare my interest as a vice-president of the Local Government Association. My noble friend Lady Grender mentioned councils and right-to-buy receipts, but unfortunately she did not get a reply, so I will reiterate her point. To prevent the currently lamentable provision of social housing getting even worse, will the Government seriously consider the following three points with regard to right to buy? Will they consider allowing councils to keep all their right-to-buy receipts; or allowing an extension of the time limit in which councils must use those receipts, preferably to up to five years? Finally, only 30% of the receipts that the Government currently allow councils to spend can be spent on building replacement homes. Surely it is time to allow all the money to be spent on building much-needed social homes.
I note the noble Baroness’s comments on right-to-buy provisions and the specific points she raised. However, the Government have an enviable record in the delivery of homes, delivering 241,000 additional homes in the last year, the highest level for 30 years. Over the last 10 years, 450,000 affordable homes have been delivered, so we are seeing more homes built of all types and tenures. We need to recognise that achievement, but I note the points on right to buy.
I commend the Government on their support of rough sleepers and their categorical promise that they will not put those people back on the streets. Has the Minister looked into the possibility that there may well be half a million people unable to pay their rent or mortgage after the Covid-19 pandemic? Will we make sure that we keep these people indoors? If they get evicted or become homeless, that is when the bills and the disruption really take off. I do not want to see another generation simply replace the current rough sleepers who have been removed from the streets.
The noble Lord made a very powerful speech on rough sleeping last week and I learnt a lot about the generations of people who were not well served by successive Governments. I note his call for a bold plan to end rough sleeping, finally, and his concerns, which are quite right, about the people who have suffered great economic loss during the pandemic. That is why we need to reopen the economy as safely as we possibly can and in a way that does not cause a second peak. The department is reviewing the situation with regard to evictions, but no decision has been taken yet.
Does my noble friend agree that there is a real opportunity and an urgent need to increase the use of digital technology across the construction sector, not least in the supply chain, to ensure that the various industry bodies produce the skills and talent to enable us to flourish in all our digital futures?
I thank my noble friend. There is no doubt that, like all others, the construction industry needs to embrace digital solutions in the digital era, which will help to ensure that construction is safer going forward.
I welcome my noble friend to his ministerial position. I commend the Government on their proposals to provide help for private tenants. However, we need to recognise that many tenants’ rent arrears will grow over time, causing problems not merely for them but for small private landlords. Will my noble friend the Minister consider a scheme like that of the Spanish Government, offering tenants low-interest loans to help them to pay the rent and the landlords to receive it?
I thank my noble friend for her comments. We can learn from the experiences of other European countries—particularly Spain, which is providing those low-interest loans. I will take that point up with officials in the department.
My Lords, I declare an interest as chair of the National Housing Federation. Housing associations had hoped this year to invest £16.9 billion in developing 50,000 new homes to rent and buy. That is now at risk. They can play a huge part in the recovery by building affordable homes, supporting local businesses and helping the Government to meet their ambitious target for housebuilding. Can the Minister assure the House that he will listen carefully to calls for significant government investment to build 145,000 social and affordable homes each year to meet our country’s needs?
The noble Baroness is right: registered social landlords play a huge part in housebuilding, and their important part in our future provision of affordable homes of all types continues. That goes for private sales by owners, too. I have already stated that there is an affordable homes programme of some £12.5 billion over the next five years. We will work closely and engage with the industry. I thank the noble Baroness for her comments.
Is it not the sound truth that successive Governments over the last 30 years have allowed our housing sector to be distorted to its present state where young people and poorer people are simply priced out? What is needed is not simply “back to business” but a real commitment by the Government to a whole new approach to housing. If I may say so, the Minister is not short of ideas to have been put to him this evening.
I thank the noble Lord for his points. He is right that housing affordability is a problem for the next generation and the one that follows. We note that, as a result of this pandemic, it is estimated that house prices have fallen by somewhere between 10% and 30%. We need to understand that the way to deal with the housing crisis is the provision of new homes and ensure that we facilitate those second moves so that the whole housing market gets going again.
I welcome my noble friend to his position, and I also welcome the opening of the housing and construction sectors. In light of the significant problems exposed by this crisis in the care home sector, which has been neglected for many years, and the paucity of suitable housing being built for last-time buyers, will my noble friend urgently investigate ways of encouraging the construction of retirement villages, where elderly residents can live separately if needed but with appropriate support should they require it?
The noble Baroness makes an important point. We need to remember that we need housing of all types, including that for last-time buyers. Countries such as Germany have invested heavily in retirement homes, and we need to ensure that that is part of our plans in future. I thank the noble Baroness for her question.
My Lords, the Statement talks about homes of all types and tenures but says very little about the affordable housing market. How will the Government ensure that the affordable housing market will sustain itself in the face of continuing hardship?
The Government have set aside an extraordinary, unprecedented level of funding of £12.5 billion, compared to £9 billion in the previous financial settlement, for affordable homes. In working with our partners, and social landlords, we recognise that there needs to be a commitment to such homes over the next five years, and the money is there to do precisely that.
My Lords, I congratulate my noble friend on his appointment and the Government on their brave move in opening up the housing market. My noble friend will be aware that his department is known for its bias towards urban property and urban issues. Given what the noble Lord, Lord Best, said, can the Minister assure me that the rural sector will not miss out under the Government’s proposals, and that there will be a big effort to provide affordable homes in rural areas?
My Lords, house prices have fallen, and many are struggling to meet their mortgage repayments due to Covid-19. Will the Government do an assessment of the number of home owners at risk of negative equity or of having their home repossessed, and the effect this will have on the economy? The furlough scheme has been extended. Will the mortgage holiday be extended too?
My Lords, I draw attention to my interests in housing and development, as set out in the register. It is critically important that we remember that, no matter what disruption Covid may cause in the housing sector in the short run, the young people who have been priced out of homes are still there. Whether they rent or buy in the future, they need a place to live. That pressure will begin again as soon as we see the lockdown end. Can the Minister make it clear that this is not just for the construction industry? It is also for local authorities to continue with their local plan processes to ensure that we deliver the homes that are needed and to ensure that those homes are of the highest quality and with the best quality place making. Local plan progress is critical to that.
The noble Lord is right that the local plan process is extremely important. As the Building Safety Minister, ensuring that we build homes of high quality is paramount to me. We will shortly be introducing into legislation the biggest shake up of the regulatory system to ensure that we have buildings of the highest possible quality.
As the Secretary of State said so eloquently in his Statement:
“A home is more than four walls and a roof. It is a sanctuary, a form of protection and the link to your community.”—[Official Report, Commons, 13/5/20; col. 258.]
Does my noble friend agree that the overwhelming need now is to move as quickly as possible to normality in the housing market and that, in ensuring the safety of everyone, as we must, we should apply the common sense that the Prime Minister has sensibly advocated?
The noble Baroness is right. It is time to return to normality as quickly as we can but we need to ensure that it is safe to do so. We need to recognise, as the Secretary of State said in his Written Ministerial Statement, that over 450 sales have been stuck in the system, unable to be addressed, and a substantial number of rentals have not gone ahead. Every month some 300,000 tenancies come up for renewal. At the same time, we know the contribution that the construction sector makes to our economy and the need to get new homes built. That needs to happen safely but it needs to happen as soon as possible.
My Lords, what discussions have taken place with the devolved institutions about the need to increase the provision of social and affordable housing to address the housing need and homelessness that will ensue following the coronavirus pandemic?
I do not have the answers to hand with regard to specific discussions. Housing is a devolved matter, as the noble Baroness knows, but I am sure that discussions between officials will happen.
My Lords, one constraint on the construction industry as it recovers from recession is the shortage of skilled workers from the EU, who have left and are unlikely to return. What steps are the Government taking to retrain with the necessary skills those who, sadly, may be made redundant by their current employers?
My noble friend makes the important point that we require all the skills of construction workers and that many of those were from EU countries. I am sure the immigration system that has been introduced by the Home Secretary will take into account our need for the skills to drive the construction industry. I can write to my noble friend with specific measures that are being taken. Obviously, we are doing what we can on this but there is nothing in particular to state at this point.
This Government recognise the importance of high streets and have injected a considerable amount of money into them. I will take up the noble Lord’s suggestion, get back to him in writing and place a copy in the Library.
Does my noble friend agree that one problem in getting a sustained supply of planning is inappropriate planning conditions? That is particularly true in two-tier areas. Is he aware that Section 106 agreements have been sought by county councils on education and highways, and these are properly already included in the community infrastructure levy, but there is some disagreement and worry that this will be passed on by the district council to the county? Therefore, where this disharmony exists, will my noble friend bring some harmony?
My noble friend is right that there should always be harmony where there is disharmony, and I will look into the specific issues regarding Section 106 payments between district councils and county councils. Many developers may have their own financial pressures but I know that many local authorities are being sensible about, and sensitive to, that and are ensuring that there is enough time for these Section 106 contributions to be made in the first place.