One of the most controversial sections of the Localism Act is section 143, which deals with local finance considerations. This makes clear that defined financial "benefits" (significantly New Homes Bonus and CIL) can be taken into account in the determination of planning applications "where material to the application". The Government has insisted that this simply states what the position already is in planning law. Of course there are cases that make clear that financial considerations can be material to planning decisions, but generally those cases have been decided in the context of planning agreements. The conundrum for all of us is will the courts regard receipts like NHB and CIL in the same way as section 106 obligations? Will it matter, for example, whether all or part of NHB is to be ring fenced for the benefit of a particular community or development - or whether it simply flows into the planning authorities account to be used for services district wide? Does "material to the application" mean simply that but for the application, the financial benefit would not arise - or does there need to be some connection between the way the benefit will be applied and the development under consideration?