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3) Conclusions and recommendations

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Key conclusions
Key recommendations

Key conclusions

  1. Relying on the private sector to progress applications through the planning system alone will not deliver against the full range of society's housing needs in a particular council area;
  2. National Government policies for housing and planning seem to pull in different directions;
  3. Each council will find its own way to provide housing, which is evidenced by the range and variety of methods now being used by a majority of councils. In our direct survey to local authorities, 69% of them reported they were directly delivering housing, whilst in our desk survey of local authorities were found that 78% had a housing or property company;
  4. Making housing a corporate priority for a council usually leads to more activity;
  5. Despite the welcome removal of the HRA debt cap, the HRA still restricts housing delivery;
  6. Homes England's role in the provision of all housing types is unclear and would benefit from replicating approaches led by the Mayor of London who is funding Councils to provide social housing accompanied by skills support;
  7. The relationships between local authorities and housing associations are increasingly variable;
  8. Local economies, as supported by Local Industrial Strategies, need all types and tenures of housing to support their success and this needs to be reflected in Local Plans;
  9. Viability negotiations and CIL are not providing the contributions expected or needed;
  10. Local authorities need access to development surveyors;
  11. Local plans should deliver on all housing needs and be found unsound if they fail to do so;
  12. Concern about the quality of housing delivered by some private developers is widespread. Local plans should be standards based to address this and support placemaking;
  13. Local plans must address existing stock and new housing to meet the climate emergency;
  14. Care is needed to manage internal relationships within the council, and external relations with communities, when the council or their company is the applicant for planning permission; and
  15. It takes time – the rise of council companies found in this research since January 2018 will take at least two years to start development and all local authority companies are starting small to learn from their experiences.

Key recommendations

As a result of our research findings, we make a series of recommendations to various stakeholders in housing delivery. The key recommendations are:

HM Treasury

  • Should allow local authorities to borrow against their assets and rent income in the same way as Registered Providers and the private sector.


  • Should revise the NPPF so that local plans will be found unsound if it is not clear how they will deliver against the different types of housing need identified;
  • Should reform the method of Objectively Assessed Need (OAN) so that is compatible with housing need in the local authority area derived through the housing strategy, homelessness strategy and the Joint Strategic Needs Assessment/ Wellbeing strategy;
  • Should recognise that the current approach to viability is not working as a test for the delivery of the range of homes required and is not fairly balanced to meet public provision;
  • Should require local plans to systematically review the housing needs of older people, in their areas, identify shortfalls and include requirements to meet them;
  • The Minister for Housing should provide Homes England with a national target for the provision of housing for older people and establish a funding and support programme to deliver it. This funding should be available to local authorities without an HRA;
  • Should act to ensure that where older people have been private tenants for a long period, they be afforded some security of tenure;
  • Should review the use classes order for housing and make applicable to the determination of each application and site for housing as for retail and employment uses;
  • Should oblige all homes provided to be at lifetime homes standards;
  • Should reverse the permitted development rights freedoms which currently allow new dwellings to be developed without planning permission, bringing such developments into full planning control with associated requirements and contributions;
  • Should return the provision of public bodies to have first refusal of land being sold by other public bodies at public values;
  • Should require monitoring of the delivery of different types of housing including for older people, families, students and PRS are included within annual monitoring reports;
  • Should remove Right to Buy (RTB) as a policy for local authority housing. If RTB is not repealed they should allow local authorities to keep all RTB receipts to use to provide replacement housing;
  • Should create specific funds for local authority affordable and social house building supported by skills funding as by the Mayor of London; and
  • Should establish a funding subsidy programme through grants for local authority direct delivery of housing whether through the HRA or other mechanisms such as an RP or on the general fund.

Local Authorities

  • Should bring together housing and planning into a housing delivery team to manage the implementation of all housing schemes regardless of the promoter;
  • Should establish a housing delivery board to monitor progress and delivery;
  • Should establish a housing delivery forum of all providers in the area to meet regularly to discuss progress and problems;
  • Should establish a housing intervention fund to help overcome issues on individual sites (funding can be made as a grant, a loan or in return for development equity);
  • Should consider how housing provision can support the local economic objectives e.g. PRS for younger professionals and graduates moving to the area, housing for families to encourage them to remain in the area, key worker housing;
  • Should assess all sites in council's ownership for the suitability for housing not just those held in HRA or in delivery portfolios; and
  • Should include more detailed housing delivery outcomes in the annual monitoring report.


  • Should produce practice advice for local authority planners on direct delivery of housing, with guidance on internal relations, negotiating contributions, and public engagement.

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