b'Section 1 simply states that: A local authority has power to do anything that individuals generally may do. This admirably concise power is designed to change fundamentally the way local government behaves, giving local authorities the same capacity to act as an individual generally has, which will enable them to do anything apart from that which is specifically prohibited. What this effectively means is that the common law position that a local authority must always identify a statutory source to empower it to undertake a particular course of action, under the new powers, an authority is provided with all the powers to do anything that an individual of full capacity generally may doa much wider potential starting point for the identification of powers than previously was the case. There are, as ever, provisos to these new freedoms which tend to complicate and cloud the extent of this (at first blush) seemingly limitless power. The devil is in the detail of the statutory restrictions but the most significant is that the general competence powers will not provide local authorities with any new power to raise tax or precepts, or to borrow. Neither will the proposals enable councils to set charges for mandatory services, impose fines or create offences or byelaws affecting the rights of others, over and above existing powers to do so. But, (or so the impact assessment states)the powers are designed to allow councils to undertake innovative activity to drive efficiency and therefore will result in thempotentiallyundertaking activity that presents some risk to the taxpayer. The Localism Act Survey, published in December 2013 conducted by the Local Government Association demonstrated that only 12% of respondents had taken significant advantage of the new powers, whereas 29% said that the new powers had not made a difference because they do not go far enough to support charging and trading, GPOC has been used for: setting up new partnering arrangements with other public sector and private sector bodies; giving eligible parish and town councils more confidence to provide services that the district or county councils are no longer able to provide; setting up financial support schemes. Since that survey, many local authorities have relied on GPOC when establishing trading companies but have taken a slightly cautious approach and often praying in aid section 95 as well. The case of R (on the application of GS) v London Borough of Camden [2016] EWHC 1762 (Admin) considered whether the GPOC can turn into a duty. The High Court considered that the GPOC can be converted into a duty on a local authority for them to provide a particular service. This case had to deal with the question of whether Camden should have used its GPOC to provide accommodation to an individual with social care needs, as to not do this may have breached the European Convention of Human Rights. It was recognised that the GPOC is subject to limitations, with the potentially relevant limitation here being that the GPOC would not enable Camden to do something it is otherwise prevented from doing. The court had to consider the Care Act 2014, and whether Camden should provide care to the individual under this Act. It held that the Care Act 2014 came into force after the GPOC and did not include a limitation, prohibition or restriction to the GPOC. Given the impact that no provision of social care would have on the applicant, the court considered that the GPOC had been converted into a duty in this 67'