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Making the Most of the Budget

17th November 2024 by newtjoh

The first Labour budget for 14 years and the first ever delivered by a female chancellor was also momentous in its expected expansionary impact on the economy (net fiscal loosening adding to aggregate demand) notwithstanding that its planned annual tax increases of around £36bn will take the share of tax to GDP to record levels.

This post reflects and focuses on its implications, according to three main headings:  the real crisis of the fiscal state; fiscal institutional reform and public investment planning and delivery (which includes investment in public (social) housing as a case study); and Labour’s 1.5m housing target – scaled down to putting the annual new supply of 300,000 dwellings onto a sustainable footing by the end of this current parliament.

The Autumn Budget 2024 Treasury Red Book (Red Book) and the Office of Budget Responsibility (OBR) October 2024 Economic and Fiscal Outlook  provide its main source documents.

The fourth section, waiting for Mr Growth, notes that although the OBR post-budget assessment and its five-year forecast indicate continuing levels of stunted growth during the lifetime of this 2024-29 parliament, it does not take account of the future policy and economic impacts of the Spring 2025 Comprehensive Spending Review (2025 CSR), or of planning reform, or of the future operation of the National Wealth Fund combined with pension fund reform.

Together they will prove pivotable as to whether the actions of this Starmer government (besides external shocks and events) can and will uplift the annual growth rate towards the 2.5% level more consistent with both a sustainable welfare state and public finances.  

1             The Real Crisis of the Fiscal State

The real crisis of the fiscal state (RCFS) is the mismatch between the public expenditure requirements of the UK (assuming a continuing public desire and demand for accessible and universal public services and goods on the European social democratic model) and the political and electoral willingness for them to be met through forms of taxation that are efficient, sufficient, and transparent.

It means that the dominant political parties promise to reduce or at least not to raise taxes while also claiming that they will improve or at least protect public services that require real (inflation-adjusted) increases due to the increased demands of an aging population, higher relative costs and other related reasons.

Essentially, that is an incompatible combination with the stunted levels of growth that the UK has clocked-up since the Global Financial Recession (GFC) a decade and half ago.

The October 2024 budget (budget) followed an election where the previous Conservative government had within a six-month period twice reduced employee national insurance rates by two per cent, despite knowing that doing so would either require unsustainable future levels of borrowing or unachievable future cuts to already unrealistically low planned spending plans.

Labour when in opposition supported both these cuts (in essence, pre-election bribes) while committing itself in government not to increase headline rates of income tax, national insurance or VAT: its tax self-denying ordinance.

Notwithstanding previous and some continuing protestations to the contrary, the budget will increase taxation substantially on non-affluent working people.

First and foremost, the continuing freeze until April 2029 of income tax thresholds, to all intents and purposes, is a tax increase, chipping away both nominal and real increases in pay, bringing either into tax or into the higher tax bracket millions of extra taxpayers.

It is an expedient and effective but also an invidious, distortive, and stealthier way to raise revenue compared to increasing headline rates, raising around £28bn for the public coffers in 2025-26, rising to nearly £38bn by 2028-29.

Second, the increase in employer’s national insurance contributions (NIC) from 13.8% to 15%, made effective at a lower threshold and without a limitation of a higher threshold, is expected to raise around another £25bn annually from 2025-26 to 2029-30 (static effects not taking account of behavioural responses by economic agents), more than offsetting the £20bn reoccurring annual cost of the previous government’s successive employee NIC cuts (see OBR Table 3.9).

Workers will consequently receive lower wages and/or pension contributions than they would otherwise have done without the NIC increase.  Future real wages will be further dragged down by businesses, where and when they can, levying higher prices rather than lower profits accommodating their resulting higher costs.

Increasing in employee NIC or income tax rates instead would have had a more immediate, direct and thus salient impact on nominal post-tax employee incomes; the employer NIC increase is likely to have a more muted, delayed, and hidden although still real effect over the forecast period. The employer NIC increase is a direct and salient cost for businesses.

Where businesses take the hit of employer NIC increase through lower profits that is potentially redistributive in terms of its relative incidence between capital and labour. The lack of threshold limitation is also possibly redistributive (but less so than a direct increase in the income tax rate) although it could incentivise off-PAYE employment and other distortionary arrangements, reducing its yield.

On the other hand, the increased liability to pay employer NICs at a lower threshold combined with an increased minimum wage is likely to bear down on lower-wage workers through reduced employment effects.

According to the OBR forecast, the combined impact of the continuing tax threshold freeze and the new employer NIC increase (plus some other smaller tax increases) will take the tax take by 2029-30 to a historic high of 38 per cent of GDP, causing private consumption to fall as a share of GDP.

That, along with the short-term squeeze on profit margins occasioned by the employer NIC rise, is expected to further deflate business investment further. Already, its share of GDP is one of the lowest in the industrialised world, representing a core and chronic determinant of the UK’s stunted post GFC growth and productivity record.

On the face of it, therefore, the budget (when its policies are considered in isolation), over the medium term (essentially the five-year OBR forecast period) will not only increase taxes on working people in real outcome terms but will retard future growth: quite contrary, in effect, to the government’s avowed aims.

Labour had to win an election. Its tax self-denying ordinance and limited ambition costed fiscal pledges were made to neutralize Conservative attempts to paint it again as the ‘tax and spend’ party as happened to instructive effect in 1992, 2010, and 2015.

But it also constrained honest public debate on the fiscal situation and future choices concerning that and the state of the public realm, as well as boxing-in Labour’s own future policy maneuverability in government.

In retrospect, the public had realized intuitively that post-election tax increases were inevitable, regardless of the political complexion of the new government, and proceeded to punish successive incumbent Conservative governments for their incompetence, their poor behaviour, and their lack of delivery, while in office.

The second Conservative employee NIC cut, at least, could have been opposed as an obvious unsustainable electoral bribe. The Labour leadership, however, did not want to risk any suggestion that they would reverse any Conservative tax cut and thus increase direct tax rates; hence Labour’s self-denying ordinance and resort to alternative sources of revenue.

In short, the budget, compared to March 2024 budget plans, increased planned public spending by almost £70 billion annually (a little over two per cent of GDP) from 2025-26 to 2029-30,  split two-thirds on current and one-third on capital spending, paid for by increased taxes amounting to £36bn annually, requiring increased average annual borrowing of £32bn,  (see OBR Table 3.1 for more precise figures).

A not unsensible combination that provided a substantial real 3.3% increase in the NHS England budget (OBR Table 5.4) that when, hopefully, combined with the early beginnings of necessary embedded and continuing future productivity and efficiency gains, should provide at least a temporary respite to some of its structural funding and delivery challenges.

Yet, overall, the budget only kicked the real fiscal can down the road. In a muted reprise of Conservative fiscal dishonesty, most departments face limited increases or even real term cuts in their budgetary allocations beyond 2024-25 (subject to 2025 Comprehensive Spending Review decisions).

It yet again froze fuel duty during a period of falling fuel prices at the beginning of a government term when it can better ride out short-term negative reactions. If not now, when? Sure, an increase could have added to cost-of-living pressures (more especially in rural areas) but the new government lost an opportunity to introduce a wider narrative consistent with its decarbonization vision.

That could have included a pledge to adjust the duty with future fuel prices to smooth future net price volatility more conducive to consumer and business budgeting.  

Making the current budget balance will mean a combination of future cuts and/or further tax increases, unless future economic growth surprises on the upside (see section four).

The political risk for Starmer’s Labour government is that its own fiscal dissembling will come back to bite it, especially given the shallow popular base of its 2024 victory (its high majority was a product of the efficient distribution of its vote, not its relative volume) and the secular trend for greater electoral volatility and fragmentation.

It could have to paying a continuing and mounting economic and political price for becoming an increasing hostage to the RFCS, however much it twists and turns to escape its clutch.

The unfreezing of income tax thresholds in 2029-30 no doubt will be presented then as a tax cut pre-next election (it may also avoid the triple-lock pension being taxed when received as sole source of taxable income) amid, quite possibly, another proclaimed self-denying ordinance on future direct tax rates, thus repeating and in the process entrenching the fiscal circus cycle yet again, something that may or may not prove electorally successful.

At the end of the day, treating the electorate as children unable to grasp economic and financial realities is not sustainable in strategic political terms in either narrow party or national interest terms.

Sooner or later the music will stop, while the further embedding and entrenchment of popular distrust and cynicism pervading politics can only undermine and corrode the democratic process itself, risking destructive results.

There is no easy way of the RCFS in either political or policy terms. Few of us welcome political messengers telling us that we should pay more tax upfront or must accept reduced public service quality and coverage.

Better the pill sugared, disguised, or even better postponed, even though it might make the pain worse sometime in the future. After all, something might turn up; why put your head above parapet to be shot, until you must?

Council tax reform towards aligning payment to current housing values combined with the phasing out of housing stamp duty (see this Dan Neidle post for a clear and informed discussion) and getting the financially comfortable elderly to pay more towards their health and social care seem to provide the most obvious possible partial escape routes out of the RCFS but still involve considerable political management risk.

Certainly, at least some political groundwork should start to be laid to shift the tax burden away from productive activity towards wealth and to better link individual contribution to potential benefits received, where possible and appropriate.

Less politically challenging and more attainable sooner rather than later is making public spending more effective and productive. To that necessary but not sufficient route of the RCFS, the next section turns.  

2             Fiscal Institutional Reform to Make Public Investment Planning and Delivery More Efficient and Effective

The budget set out a two-pronged revised fiscal framework. The stability rule will require the current budget to be in forecast surplus in 2029-30 (as assessed by the OBR) until that year becomes the third year of the forecast period in 2026-27.

From 2027-28 onwards, the current budget must then remain in balance or in surplus from the third year of the rolling forecast period (for example, from 2030-31 in 2027-28).  Balance is defined as a range: in surplus; or in deficit of no more than 0.5% of GDP.

The second prong – the investment rule – will require net public debt, now defined as Public Sector Net Financial Liabilities (PSNFL), to fall as a share of the economy (GDP) by 2029-30, until, like the stability rule, 2029-30 becomes the third year of the forecast period in 2026-27.

Then to meet that rule, net financial debt (PSNFL) should fall as a share of GDP by the third year of the new rolling forecast period: 2030-31, if assessed in 2027-28.

In addition to the stock of debt that the Public Sector Net Debt (PSND) measure previously captured, the replacement PSNFL or net financial debt measure now includes financial liabilities, such as funded pensions obligations and government guarantees.

Crucially, however, it also nets off illiquid financial assets, such as equity holdings and loans, from total financial liabilities to calculate the headline net financial debt metric.

The Treasury in support of this change pointed out in its Red Book that by failing to count financial assets, the previous PSND metric could create an incentive for the government to forgo profitable and growth enhancing investments, such as that are expected to be made by the National Wealth Fund, despite any positive future impact upon the economy and their ability to yield a positive return for the taxpayer over their lifetime(s).

Yet PSNFL does not recognize the value of physical public assets, including road and railway networks, and public housing.

Its use, therefore, risks creating a new set of perverse incentives for government to make investments in financial rather than physical assets, making loans and issuing guarantees in preference to investing directly in productive assets, simply to accord with the investment rule rather than because of overall long-term value-for-money (vfm) grounds.  

Indeed, it does seem that PSNFL was made the primary debt metric for fiscal rule measurement purposes mainly because it provided the government with additional expenditure headroom in the desired format: the most expedient rather than necessarily the most optimal measure.

It did enable the budget to announce a total increase in planned public capital investment of around £100bn over the next five years over and above previously planned levels.

As the prequel to this post argued, it would, however, have been better for the chancellor to make the case for additional investment clearly, directly and transparently, according to its economic and thus fiscal sustainability merits, rather than tweaking fiscal second order rules that when political push comes to shove inevitably tend to be gamed or changed.

As way of historical context, Conservative governments in the early nineties tended to rely upon second order objectives, such as the exchange rate, to bear down on inflation rather than making low and stable inflation a first order objective supported by reformed institutional architecture as New Labour did to notable success in 1997.

Whether the new investment rule is met or not will depend upon a range of factors, including future inflation and interest rate trajectory, and growth and productivity outcomes. These the government can only at best partly influence by its own policy and other interventions.

It will then rely upon the OBR to adjudicate whether the rule is on track to be met according to that organisation’s forecasts.

At present, the OBR is only about 50% confident that its current assessment that the government post-budget has about £15.7bn fiscal headroom to meet the investment rule will prove accurate.

That headroom could vanish in a flash in the event of an external shock or be dissipated by lower than forecast growth – which the OBR has a history of over-estimating – leaving a lot to contingent hostage, including, for instance, that growth will even reach two per cent in 2025.

Whether the new investment rule is met or missed by a percentage point or so according to the chosen measurement metric of the day is unlikely to make much material macro-economic difference.

The clear and present danger rather is that investment projects that would generate returns over their cost of provision (including their capital opportunity or cost of capital costs) will be shelved, delayed, or pared back simply to keep within the investment rule target three to five years thence, according to forecasts and assumptions that may or may not be realised that invariably can shift with the short-term economic environment and its associated noise.

Undoubtedly the government must maintain wider market confidence that its fiscal position is sustainable. Otherwise, interest rates will rise, sap growth, and offset or dissolve the benefits of such productive public investments.

But the investment rule sidesteps the imperative to increase effectively selected and prioritised productive levels of public investment closer to economically optimal levels requiring chosen programmes and projects to be both efficiently selected and delivered.

The budget did announce some steps and “guardrails” to ensure improved investment outcomes, including:

  • publishing a 10-year infrastructure strategy alongside phase two of the forthcoming spring 2025 CRS, outlining the government’s long-term approach;
  • setting five-year capital budgets and extending them every two years at regular spending reviews, to “provide more certainty”;
  • increasing the transparency of investment decisions by publishing the business cases for major projects and programmes.

At a more substantive institutional level, the National Infrastructure and Service Transformation Authority (NISTA), combining the functions of the existing National Infrastructure Commission and the Infrastructure and Projects Authority, will be made operational by spring 2025.

NISTA will then become responsible for implementing the government’s infrastructure strategy, validating business cases, prior to HM Treasury funding approval.

The budget also finally announced the formal launch of the Office for Value for Money (OVM), with the appointment of an independent Chair, who as a first step, will advise the Chancellor and Chief Secretary to the Treasury on decisions relating to the multi-year spring 2025 CSR.

The wider remit of the OVM will include an assessment of where and how to root out waste and inefficiency; the undertaking of value for money studies across high-risk areas of cross-departmental spending; the scrutiny of investment proposals to ensure they offer value for money; as well as working with the National Audit Office (NAO) to benefit from that organisation’s scrutiny of capital projects to learn lessons for application to future projects.

Although these represent potential steps forward, the respective roles of NISTA and OVM are not clearly demarcated and appear to partly overlap.

A potentially more fundamental and possibly related possible shortcoming is that they are not statutorily defined as entities independent of the Treasury, even though their future effectiveness will depend on their own institutional clout and resourcing.

Their creation and development should have been and should now be made central and integral to the government’s overarching growth mission and commitment to economic and fiscal sustainability – not a subsidiary budget add-on.

The long-term impacts of public investment: social housing as a case study

The OBR has estimated that the additional public investment over and above the previous government’s plans as announced in the budget should directly increase the total potential output of the economy after five years by 0.1%.

That could increase to 0.3% after ten years if the planned increase is maintained, as the resulting output effects rise over time while implementation time lags recede.

If that increase further levers-in complementary private investment and human capital upskilling, the GDP uplift could reach 0.4% after ten years and 1.4% after fifty years.

However, the OBR believes that the economic benefit of the increased public investment will prove more muted due to the impact of higher public borrowing on interest rates and the associated limited complementarity crowding-in of private investment.

Although it should increase incentives for businesses to invest, that broader crowding out effect of the budget’s net fiscal loosening, driven by a sustained increase in real government spending as a share of GDP within a capacity-constrained economy, is forecast by the OBR to reduce business investment by the end of the five-year period.

Such conclusions, including the differential macro-economic impact of different categories of public spending, such as public investment and government spending on current services (consumption), are dependent on the econometric assumptions that the OBR applies, based on its interpretation of the empirical literature. 

Alternative interpretations of that literature, such as here, have queried whether the OBR’s assumptions on the impact of public investment through its fiscal multipliers on output, and on the future total supply capacity of the economy (and thus its ability to absorb increased output without inducing inflation), are too conservative.  

Moreover, public housing investment is singled out by the OBR as less growth enhancing than alternative investments in enhanced economic infrastructure, including on transport networks, on water supply, and on sewerage, implying that its net economic effects could be negative over the long term.

As way of contrast, an October New Economics Foundation paper argued that as public grant supported social housing would not otherwise be built, the socio-economic returns that it generates is higher than private housebuilding.

It cites the high construction multipliers associated with housebuilding (for every one pound generated directly, a further £1.43 is generated indirectly and through wider spending in the economy) on top of tenure-specific social returns linked to lower housing benefit expenditure, reduced homelessness and family dislocation, and through its employment-enhancing effects increasing taxation receipts and reducing social security expenditures,

In sum, according to the NEF, building 365,000 social homes – the minimum number it assesses are needed to deliver the government’s 1.5m housing delivery target – would yield, aggregating all the above gains, total gross economic and social benefits of around £365bn over 30 years.

Net of public investment costs – in terms of central government grant and local authority expenditure – its total net benefit is posited at £225bn over three decades, with every one pound of the up-front public investment required to deliver that volume of social housing generating more than £2.60 for the wider economy in return.

The paper links a rising proportion of that overall economic benefit exclusively to the social rent sub tenure (let at around 50% of market rents depending on location) with 43% (£158bn) of this total gross economic and social benefit attributed specifically to that sub tenure.

That final net benefit figure reflects proposed changes to the social discount rate (SDR) currently applied in accordance with Treasury Green Book methodology.

An SDR of two per cent applied to social housing investment, less than the Treasury’s current standard 3.5% – still above Germany’s SDR and in line with the general US government SDR, which was reduced to two per cent earlier this year – would result in the 365,000 social housing programme generating £50bn more in net present social value benefits compared to the current Treasury approach.

These results, of course, are like the OBR’s, predicated on organizational and study-specific assumptions applied, which likewise, are challengeable, especially when they are drilled down on.

No account is taken of the likely crowding-out effects of such a programme. Leaving aside, the possible impacts of resulting higher levels of borrowing on interest rates, its impact on a capacity constrained construction industry is almost certain to lead to material and skilled labour bottlenecks and resultant sector-specific inflation – at least in the absence of concerted and focused public interventions undertaken in partnership with industry suppliers in step with its scaling up. 

The NEF paper also assumes that the overwhelming demand for social housing will mean most of the economic benefit of investment in social housing is likely to be realized.

That, to say the least, is a heroic assumption. Based on past empirical experience of employment levels within the Social Rent (SR) sub-tenure, it is far from certain that, in practice, an expanded SR programme by itself will increase overall economic activity levels.

Although reduced levels of homelessness can be reasonably expected, social returns relating to family stability and improved health will prove more difficult to demonstrate rather than to state and assume.

An extended 30-year period is especially prone to uncertainty and confounding impacts, and so on.

The NEF study, did, however, clearly explain and define in plain English its underlying assumptions rather than rely, as the OBR tends to do, on econometric equation notation unintelligible to most lay audiences (the NEF paper’s appendix on social discounting is a commendable model for general replication).

What can be more safely concluded is that the economic and social impact of an expanded SR programme is a highly important and relevant issue that requires and needs further dedicated evidence-led and transparent scrutiny and assessment.

This is where both NISTA and the OVM could and should play pivotal and instrumental roles. 

 3           Labour’s Housing Delivery target

The chancellor in her budget speech termed Labour’s 1.5m housing delivery target as “a commitment”, which was worrying insofar that it rather suggests that she does not understand that it will not be achieved for the reasons explained here.

It risks becoming a distraction from the more sensible and realistic goal of laying the foundations of a sustainable 300,000 annual new supply level by the end of this parliament in 2029.

Most commentators consider that to meet the existing and future needs of those not able to afford market costs, an annual and sustained Social Rent (SR) programme level of at least 90,000 dwellings in England, plus another 30,000-50,000 of intermediate sub tenure, is required.

That roughly corresponds roughly with what is consistent with the achievement of a sustainable 300,000-plus annual new housing supply in England, assuming that annual private speculative market supply, going forwards from 2027-28, can be sustained at the 170,000-180,000 dwelling level (see previous link for more detail).

The budget did announce a £500 million uplift to the 2021-2026 Approved Development Programme (ADP) – from which public grants to support affordable housing provision are made – increasing its 2025-26 budget to £3.1 billion, while making the claim that is “the biggest annual budget for affordable housing in over a decade”.

It should, according to the budget announcement, enable 5,000 additional (SR + intermediate) affordable dwellings to be provided, over and above previous plans. An average unit public grant support of 100K is thereby implied, suggesting that most of these newly provided dwellings, if delivered, will be let at SR levels within high cost and high need metropolitan areas.

Putting that into context, recent annual levels of SR provision are running at around 14,000 , which even if increased by 5,000, will remain way below the above required 90,000 level.

Stepping up to that would require additional annual public grant support, phased up and then sustained in the £4bn to £10bn range. Precise future funding requirements will depend on the location and the provision outturn costs of the units provided, as well as on the future relative contribution of S106 affordable housing obligations to the 90,000 dwelling total.

The chancellor went on to confirm that “to deliver on the commitment to get Britain building”, the government in the spring 2025 CSR will set out further details of future grant investment allocations beyond the current ADP and that these will run for at least the duration of this parliament and support a mix of tenures, with a focus on delivering homes for SR.

Clearly, the spring 2025 CSR housing settlement will prove pivotably crucial to the government’s housing ambitions. The budget advised that the CSR will take a “mission-led, reform-driven, technology-enabled approach to funding public services, while investing in long-term growth”.

We can only wait and see the outcome of that late next spring, which should allow us to model more definitively expected levels of affordable provision and its contribution to the government’s delivery target to the end of this parliament and beyond.

In that light, it is unfortunate that the fiscal institutional reforms that the preceding section discussed are unlikely to be operative in time to comprehensively contribute within the forthcoming CSR to a more evidence-led and transparent consideration of the economic and social benefit of additional SR and intermediate provision relative to their up-front public investment costs.

Hopefully, however, that consideration is accorded sufficiently high priority within both the portals of the Treasury and the nascent NISTA and OVM, for a useful stab in that direction to be made.

Other housing fiscal measures that the budget announced included providing an additional £233m to prevent homelessness, taking total spending to one billion on that in 2025-26, an increase designed to prevent rises in the number of families in temporary accommodation and to reduce rough sleeping.

An additional £3bn was also announced to support for SMEs and the Build to Rent sector in the form of housing guarantee schemes, designed to help developers to access lower-cost loans and to support “the delivery of tens of thousands of new homes”.

At a more micro level, £10m of funding was assigned to enable the Cambridge Growth Company to develop an ambitious plan for the housing, transport, water and wider infrastructure to unlock and more fully realise the economic growth potential of that high value-added sub region.

Curiously, housing benefit housing allowances were frozen. Although that might offer central government a revenue saving, it can only be expected to add rather than reduce homelessness problems and their associated revenue costs that largely fall on cash strapped local authorities.

Perhaps, the freeze is a precursor to a wider strategic drive to shift low-income tenants out of insecure private rentals and into SR at a lower public HB cost, which the 2025 CSR will progress as part of a wider housing strategy. It is , however, rather suggestive of non-joined up thinking that will have arbitary results.  

This is another issue that could benefit from some future OVM scrutiny and NISTA consideration analysis of the longer-term cost-benefit consequences of such a shift from the PRS to SR.

4       Waiting for Mr Growth

The government has confirmed that this and future budgets will be a once-a-year fiscal event focused on tax, spending, and borrowing decisions only, separate to the government’s wider growth-enhancing strategy and decision making. 

The OBR forecasts that the economy to grow by 1.1% in 2024, increasing to two per cent and 1.8% in 2025 and 2026, before returning to around the OBR’s current estimate of its sustainable non-inflationary potential growth rate of around 1.5%, 1.5%, and 1.6% in 2027, 2028, and 2029, respectively, remaining below pre GFC levels. Such levels would generate insufficient resources to reset public services for a rising and ageing population onto a sustainable path.

Even these muted levels may not be realized. The OBR has a forecast track record of optimism bias. Evidence of private sector ‘animal spirits’ or even confidence is currently difficult to discern, as are drivers to uplift private consumption, investment, and productivity.

Trumpian trade tariffs and the risk of further international instability in the Middle East and Ukraine represent further downside risks.

The main expected contributor to growth, higher government consumption, unlikely by itself to materially improve productivity and sustainable growth, and will be dependent on 2025 CSR decisions and outturns.

As Section Two discussed, increased public investment, although expected to have a short-term positive impact on GDP will, according to the OBR, have a limited and slow impact on longer term growth outcome due to low or even negative complementarity (crowding-in private investment) and output/fiscal multiplier effects, although, as the preceding section discussed, the assumptions used in the in-house study that the OBR used, determining that result, appears pessimistic.    

Moreover, OBR forecasts take account only of already announced government policies and their expected impacts, not possible future policies, such as changes to the National Planning Policy Framework that the new government proposed in July 2024 that together with wider planning reform and future National Wealth Fund activity, the government is relying upon to catalyse an upward shift in the future growth trajectory.

The OBR did recognise in its budget outlook that future planning reform when finalized and implemented could result in its housing supply forecast proving pessimistic, providing an additional domestic growth driver.

However, planning reform alone (see previous link) will not result in the government’s flagship 1.5m delivery target being met.

Although it might succeed in pushing up the number of planning permissions granted above its current historically low levels, their translation into future housing construction activity will be uncertain and partial.

The current private speculative housing model is predicated on the secure prospect of rising house prices and the ability of dominant suppliers to dribble out supply to maximise margin not volume. On the public delivery side, it is unlikely that CSR 2025 will provide increased allocations anyway near consistent with a new annaul supply step increase to 300,000 dwellings in England.

The next generation of New Towns will not come on stream substantively until the next decade. Their funding and provision models will need to be developed over the next year or so in such a way that public investment inputs can be stretched and private investment levered in.

The National Wealth Fund as a source of pump-priming investment supported by pension fund reforms – if they prove effective and timely – could allow a shift to a partial public contracting partnership model – something the change to PSNFL measurement metric (see section two) could help to enable in public accounting terms.

But, in truth, the public action way forward to higher growth is currently hazy and undefined.    

Some minor editing changes ti improve clarity were made on 24th November to the orginally posted version.

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Filed Under: Economic policy, Housing, Real Fiscal Crisis of the State Tagged With: housing, planning, public finance and budgets

Making Sense of the English Housing Statistics

3rd August 2024 by newtjoh

Introduction

This extended post publication signposts readers to the official sources of key housing statistics predominately collated and reported by the Ministry of Housing, Communities and Local Government (MHCLG), with some wider reference to UK-wide statistics that the Office of National Statistics (ONS) reports, as well as to other sources, where appropriate and illuminating, most notably the 2022-23 English Housing Survey (EHS).  

It is a comprehensive recast, extension and update on Making Sense of the Housing Supply Statistics published last year on this website and now includes six sections, each provided with a commentary provided populated with links to relevant tables reporting the source data and to a summary identifying possible policy implications.

Sections One to Four review the four main relevant source housing supply time series published by the MHCLG: the housing supply, net additional dwellings (net new supply), the dwelling stock, the affordable housing, and the often-neglected social lettings series.

These sections focus on the most recently published MHCLG affordable housing (December 2023), social letting statistical series (January 2024), and the dwelling stock estimates series (May 2024).

Section Five covers the MHCLG indicators of new supply series (termed in this post new housebuilding estimates and new indicators of supply and final tenure estimate series for reasons it explains).    

Section Six focuses on house prices, private rentals, and affordability data.

The aim, first, is to provide a user-friendly guide to the availability of such statistics and their most appropriate application and use depending upon the purpose of the enquiry, without being overwhelmed by detail.

Second, to provide structured and evidence-based context for independent policy analysis across the new policy environment that has been ushered-in by the 2024 general election.

Links to the source data mean that readers can always access it to assist user-led interpretation and on-going reference and review.  

They are also provided to interactive dashboards published by the MHCLG within their respective series and to the House of Commons Library that will allow readers to access data (sometimes incomplete) at an individual local authority level with a touch of a mouse

The post includes some new initiatives, including:

  1. Table-1A collated by this website from different MHCLG sources provides a time series for the 2011-23 period providing an average per 1000 dwellings new supply figure, by region. This was felt to be important given the wide variance in dwelling supply that exists between local authorities (LAs) often unrelated to local demand or need;  
  • To partially relieve the lack of a definitive official data tenure-based net new supply source, at least at a stock rather than flow level, Annex Table Three, itself derived from MHCLG dwelling estimates series table 104, breaks down annual net changes to dwelling stock to sub-tenure, including renting from local authorities;
  • Table 3A is designed take account of, and to statistically adjust for, the shift away from Social rent (SR) provision towards government Affordable Rent (AR) to provide more like-for-like decadal supply comparisons;
  • Tables 5A and 5B  and accompanying commentary projects 2024-27 new build completion and supply outcomes with reference to the new government’s 1.5m delivery target.     

Some housekeeping points: all data and commentary refer to England unless otherwise stated.

The UK Housing Review provides information at the Great Britain and at an individual country level for Wales and Scotland.

More detailed information for London can be found in the Greater London Authority’s  Housing in London publication.  

The labels (Private) Registered Provider (RP), more commonly known as Housing associations (HAs) are used interchangeably. Section Three provides more definitional information, including the distinction between ‘social rented’ dwellings and dwellings let at Social Rents).

Many table references will include references to the Department of Levelling Up, Housing and Communities when compiled prior to the 2024 general election and the subsequent departmental name change.

Numbers, depending on the nature of the data, have been rounded to nearest thousand or million as appropriate and percentages to the nearest single data when prefixed “about” or to the nearest single figure, percentages normally to one decimal point.

The direction of travel or trend is often more illuminating that a falsely precise figure subject to sampling or other methodological issues, to incomplete and patchy returns subject to later revision. Round figures also sometimes stick in the memory more. 

Decadal averages are employed in the tables as much as possible to illuminate longer term trends and five-year averages for shorter term ones.

Annual and even more so quarterly figures should not be considered in isolation, given their proclivity to funding programme cycles and other contingent factors.                                                                                                   

Comments and observations are welcomed to asocialdemocraticfuture@outlook.com.

1          Housing supply: net additional dwellings (net new supply) series

The net new supply series is presented by the MHCLG as the primary and most comprehensive available new housing supply metric for England. This is for two primary reasons.

First, it includes changes to the stock other than from new build completions, which can be higher or lower than net new supply. The measure thus records the complete flow of net additions or losses that add or subtract from the total dwelling stock.

The large-scale post war slum clearance and redevelopment demolitions that marked the 1961 to the 1980 period meant that net new supply lagged new build completion totals, when, across recent decades, gains to the stock from net conversions and from net changes in use have tended to outpace losses from demolitions, resulting from annual net new supply exceeding new build completion totals.

Second, as the MHCLG technical notes that accompany the series set out, its method of compilation is more comprehensive and accurate.

LAs outside London are expected to record all the changes to the housing stock within their areas over the previous financial year, before inputting them into what is officially termed a standardised housing flows reconciliation (HFR) form for submission no later than the subsequent September.

The Greater London Authority (GLA) collates similar information from the London boroughs.

Each LA, therefore, has up to five months from the end of the financial year to submit their annual HFR return. This compares to the much shorter six-week submission period connected with the building control based quarterly new housebuilding series, described in Section Five.  

By having more time to reconcile diverse potential sources of completed new build activity, including from council tax, building control and other records, as well as site visits, LAs can consequently compile a more complete and comprehensive count of additions to their local stocks.

Each November successive to the preceding financial year, the MHCLG publishes a housing supply (net additional dwellings) statistical release and an updated set of accompanying live tables that together describe changes to the net supply position.

The latest such release published in November 2023 reported net supply change between 1 April 2022 and 31 March 2023.

It also utilised 2021 census data to rebase the total annual net supply figures to the change in the total dwelling stock by enumerated by the 2011 and 2021 censuses.

58,860 dwellings additional to the aggregated net supply figures previously reported by the series, as identified in the 2021 census, were added to the stock.

This was done by making a constant 5,880 to the annual 2012-21 net additions (supply) figures, much smaller than the annual 16,190 census adjustment uplift made across the previous 2002-11 period.

The latest 2021 census dwelling count now provides the baseline for succeeding net supply and dwelling stock estimates (see next section) until the next adjustment is made to both series to reflect the future 2031 census total dwelling count.

The components of total net supply, including new build completions, however, are not census-adjusted and remain based on historic annual net supply LA statistical returns (see Annex Table One).

Figures reported for 2022-23 figures are provisional, subject to revisions to be reported in the next November 2024 release.

Revised data from 27 LAs resulted in an increase of 1,646 net additional dwellings recorded for 2021-22.

Live Table 118 of this net supply series reports total annual net additions, by region, since 2000-1, taking account of successive census decadal adjustments, according to its components since April 2006

Table 120  also breaks down the different annual components of net supply since April 2006, including:

  • new build completions;
  • conversions from houses to flats;
  • net changes to the dwelling stock resulting from gains or losses,
  • from 2015-16 onwards, changes in use resulting from permitted development rights have been separately catalogued
  • any retrospective census adjustment, when applicable and known.

Demolitions are then subtracted to provide the annual total net new additions (new supply) figure.

The immediate short story conveyed by Annex Table One is that annual net additions (new supply) steadily rose from 146,700 in 2001-02 to 223,500 in 2007-2008.

The impact of the Great or Global Financial Recession (GFC) then drove a collapse to an ultimate new supply floor of 130,600 in 2012-13.

Subsequently annual new supply steadily recovered to reach a peak of 248,600 in 2019-20.

Although it has subsequently dropped back, during the most recent 2018-23 period, annual new supply averaged 236,600 dwellings during that period, the highest five-year average recorded since the series began.

It should, however, be borne in mind that in England, the population grew by almost 3.5 million (6.6%) between the 2011 and 2021 censuses to 56,489,800 people, increasing the pressure on the housing stock.

212,600 new builds were completed in 2022-23, accounting for about 90% of the 234,400 total net supply increase reported for that latest year.

Net change in use attributable to permitted development rights (PDRs, which allow change of planning use without formal planning permission) accounted for 18,900 of the 37,900 total change in use total in 2016-17.

In the latest 2022-23 year such PDRs accounted for 9,500 (7,900 reflecting changes in office to residential use) of the total 2022-23 net change to the residential use 22,800 dwelling total (see columns C and D, Annex Table One).

Demolitions, which are subtracted from the net additions total, have fallen progressively and continuously from 22,300 in 2006-2007 to 5,500 in 2022-23.

Table 1  confirms that about 90% of new supply during the last two 2021-23 years are accounted for by new builds, compared to about 82% in 2016-17, when numbers in net changes in use, including those resulting from the newly liberalised permitted development rights peaked, giving rise to concern about the size and quality of some of the additional residential dwellings provided through that route.

Even though new build completions and total new supply may have reached a peak in 2018-20, the table shows that they still fell well short of the prevailing 300,000 new supply target.

It also demonstrates the proneness of net new supply and its components to fluctuate in a lagged response to wider macro-economic and housing market conditions.

Net supply in 2012-13 (reflecting the collapse of private speculative activity during and in the wake of the 2008-10 global financial recession) was barely half of the recovered 2018-20 level.

MHCLG Tables 122 and 123 reports total net additional supply by LA district and their component flows, respectively, since 2001-2.

MHCLG Table 124 reports annual changes in the flows of communal non-self-contained accommodation by LA district.

These changes are separate to and are not included in the other tables or the net supply figures, which only records self-contained accommodation in accord with the census definition.

The House of Commons library has produced a very useful online housing supply dashboard in which users at a touch of their mouse can access and print net new supply data for individual LAs covering the most recent ten year reported, or as  users require.

Alternatively, the MHCLG’s own interactive dashboard can be consulted.

Although it is less print-friendly, it does report net new additions (supply) broken down into its components at a local LA level, as well as at regional and national level, on a per 1,000 dwellings basis, for individual years.

It does not, however, allow users to derive average per 1,000 dwelling figures over an extended period, in contrast to year-to-year comparisons.

These can mislead due to the frequent lumpiness of new supply at the local level, connected, for instance, to a completion of a large development in a particular year.

Examples taken from two regions, the East Midlands and London, demonstrate that clearly.

The MHCLG net supply interactive dashboard reports that net new supply per 1,000 dwellings across the Nottingham City Council area in 2022-23 was 14.3 (reported here to nearest decimal point): much higher than the 4.9 reported for 2020-21 and nearly six times its 2011-21 decadal average figure of 2.4.

Net new supply per 1,000 dwellings across the East Lindsey council area (second largest by area for England; mainly rural but including market and coastal towns, such as Louth and Skegness) in 2022-23 was six, nearly than five times less than its 2011-21 average of 30.2.

In London, Barking and Dagenham, net new supply per 1,000 dwellings in 2022-23 was 15.9 compared to 4.7 as recently as 2017-18.

Table-1A collated by this website from different MHCLG sources provides a time series for the 2011-23 period providing an average per 1000 dwellings new supply figure, by region.

It reports the 2011-21 decadal average and the most recent half decadal 2018-23 average, as well as individual years 2011-23, all by region.

The data shows both some intertemporal (between individual years) and spatial (between regions) variation, although less than one would expect if new supply performance was more closely aligned to relative demand.

Taking the half decadal 2018-23 average as the benchmark, London reported the highest 10.9 average per 1,000 average and the North East the lowest, 7.1, within an overall England average of 9.6.  

Such region-wide averages mask much larger differences occurring within them.

Whilst the incompleteness of data coverage reported at that local level should be borne in mind, the range of performance that can be displayed between even neighbouring authorities is striking, noting that due to the often lumpiness of new supply at a local level, decadal or half decadal rather than individual year figures should be considered, as was explained above.

The 2011-21 decadal average for East Lindsey, for example, was 30.2, when for North Kesteven it was 10.3. In Lincoln, it was 5.6.  

In London, the 2011-21 decadal average for Richmond (in London) was 3.6 while in neighbouring Hounslow it was 10.4.

The decadal average in Tower Hamlets was 22.7 compared to 13.4 across the river in Southwark.

There is no necessary relationship between such outcomes and local housing need and demand.

Summary

Since April 2006 the net supply series identifies and measures the different components of net new supply, including new build completions.

It consequently provides the primary and most comprehensive and accurate available statistical record of the different components of new supply at both national and LA levels, consistent with the census definition of a self-contained dwelling.

The series, however, is only published annually in November for the preceding financial year; given that and because it does not cover dwelling starts, it is not forward-looking.

Accordingly, to obtain a more timely but imperfect indicator of new build completions for the year preceding November publication of this series and of future activity, the demonstratable inaccurate new housebuilding series must be consulted (see Section Five, new housebuilding and new indicators of supply section for a full discussion).

The net supply series also does not break down the reported net supply total by tenure, a significant omission insofar that gross reported new affordable supply greatly exceeds net new affordable supply – as the affordable housing series sub-section in Section Three will later show and discuss.

However, the next and successive sections will also identify sources that can be used to overcome at least partially that and related shortcomings.   

2          The dwelling stock series

The dwelling stock series reports total stock estimates back to 1801, when the first census took place, and, from 1961 onwards, also its tenure breakdown.

This series is published each year in May to include data for the past but one 1 April to 31 March period: the May 2024 statistical release (see below) and accompanying tables accordingly reports dwelling stock data for 2022-23.

Until April 2000, the annual dwelling stock estimates provided the source of the annual net additions figure. That, hitherto, had not been separately produced as a standalone series.

From 2000-01 onwards, the annual total dwelling stock estimate has been equal to the previous year’s dwelling stock estimate plus the latest annual net new supply of housing figure.

The total dwelling estimate is broken down (disaggregated) into owner-occupied and private rented sector tenures and into ‘rented from’ local authority (LA) housing and housing association (HA) sub-tenures (together, social housing).

This is done using periodic survey data mainly for the owner occupied and privately rented sector split, including the English Housing Survey (EHS), Labour Force Survey (LFS), and the Local Authority Housing Statistics (LAHS)  and the Statistical Data Return (Regulator of Social Housing) returns for the social housing sub-tenure split.

The private housing stock is not split into owner-occupied and private rented sector at the local authority district level, however.

Dwellings are defined in line with the census definition: a self-contained unit of accommodation where all the rooms (including kitchen, bathroom, and toilet) in a household’s accommodation are behind a single door that only that household can use.

A dwelling therefore can consist of one self-contained household space or two or more non-self-contained household spaces at the same address.

Ancillary dwellings (for example, ‘granny annexes’) are included provided they are self-contained, pay separate council tax from the main residence, do not share access with the main residence (for example, through a shared hallway) and that there are no conditional restrictions on occupancy.

Communal establishments providing managed residential accommodation, are not counted. These include university and college student, hospital staff accommodation, hostels/homes, hotels/holiday complexes, defence establishments (not married quarters) and prisons.

But purpose-built (separate) homes (for example, self-contained flats clustered into units with four to six bedrooms for students) are included in the dwelling estimates, with each such self-contained unit counted as a dwelling.

Non-permanent (or ‘temporary’) dwellings are included if they are the occupant’s main residence and when council tax is payable on them as a main residence.

Such dwellings can include caravans, mobile homes, converted railway carriages and houseboats.

Permanent gypsy and traveller pitches are also be counted as dwellings, if they are, or likely to become, the occupants’ main residence.

The series technical notes provide more background information.

Shared ownership dwellings are currently counted as owner occupied within the dwelling stock series.

The English Housing Survey (EHS) estimated back in 2019–2020 that there were around 202,000 households living in shared ownership properties in England (could be closer to 250,000 in 2022-23), representing approximately one per cent of homeowners and less than one per cent of all households.

The dwelling stock estimates series also does not split PRS properties into sub-tenures, including to buy-to-let (BTL) and build to rent (BTR), nor does the EHS for households, although both sub-tenures are important segments of the housing system.

Table 56 of the UK Housing Review reported that in 2022 there were over two million BTL mortgages outstanding in the UK compared to 836,000 in 2006 and less than 30,000 in 1998, suggesting that is now home to around two million households and to around 45% of private renters: a momentous economic and social change that deserves some attention within the official statistics and wider analysis.

The BTR sub tenure comprises homes built for private market rental. Industry sources suggest that there are around 100,000 BTR dwellings, most of which are concentrated in London and other metropolitan centres.  

Dwellings classified as ‘other public’ include dwellings owned by government departments, such as Ministry of Justice and of Defence. These can be vacant awaiting sale or redevelopment.

As Section 1 explained, both the dwelling and net new supply series are subject to a decadal retrospective and a new baseline census adjustment, usually applied in the year following each successive census.

In that light, the technical notes (scheduled revisions) of the May 2022 statistical release reporting for the year and period ending 31 March 2021 advised that a level 5,880 dwelling upward adjustment to the previous reported annual dwelling estimates for the decadal 2011 to 2021 period had been made, reflecting the 58,880 self-contained dwellings enumerated by the 2021 census that were additional to (on top of) what the new supply series had had previously reported for that decadal period, thus mirroring the adjustment made to that series.

In short, the adjustment ensured that the total dwelling stock estimate for 31 March 2021 equated to the 2021 census total dwelling count.

The end March 2023 figures were reported in the May 2024 statistical release.

This reported that there were 25.4m dwellings in England, as of 31 March 2023, an increase of 234,400 dwellings or 0.93% on the previous year (an increase corresponding to that reported in November 2023 net new supply (additions) series, (see Annex Table One).

Other headline results (reported to nearest 100,000; for example, LA stock figures reported as 1.6 million below were reported as 1,571,000, in Table 100) were:

  • 16.3m dwellings were owner-occupied dwellings, an increase of 176,000 dwellings on the previous year (64.1% of total dwellings compared to its 69.5% peak in 2001);
  • 4.9m dwellings were private rented dwellings (19.4% compared to its recent peak of 20.3% in 2016) an increase of 35,000 dwellings on the previous year;
  • 4.1m dwellings (16.3%) were social and affordable rented dwellings (combined Private Registered Providers (RP) and Local Authorities figure), an increase of 25,000 dwellings on the previous year, of which 2.6m. were rented from Private Registered Providers (also known as Housing Associations) and 1.6m. dwellings were rented from Local Authorities.  
  • 31,000 dwellings (0.1% of total) were other public sector dwellings, a decrease of 2,000 dwellings on the previous year;
  • 699,126 vacant dwellings (2.8% of total) were recorded in England on 2 October 2023, an increase of 22,822 or 3.4% from 676,304 on 3 October 2022;
  • 261,474 dwellings were long-term vacant dwellings in England on 2 October 2023 (one per cent of total), an increase of 13,325 or 5.4% from 248,149 on 3 October 2022.
  • England had a dwelling density of 1.95 dwellings per hectare as of 31 March 2023

All figures are rounded (as above), are provisional and are subject to revision. They are estimates rather than precisely accurate, as are most official statistics.

The latest English Housing Survey (EHS) provides information on tenure at the household rather than dwelling level, but, to all intents and purposes, mirror the dwelling estimates.

Owner occupation remained the largest tenure group in England (65% of households) in 2022-23, the social rented sector the smallest (16%) including 10% or 2.5 million households rented from housing associations, and 6% or 1.5 million households from local authorities, while the private rented sector has hovered around a similar proportion (19%) since 2013-14.

Unsurprisingly there were regional variations:

  • 31% of households in London were private renters, compared to 17% in the rest of England;
  •  21% of London households were social renters, compared to 16% in the rest of England, with the 10% proportion renting from a local authority much higher than across England generally (6% as above);
  • 49% of London households were owner occupiers compared to the 68% who were across the rest of England. 

MHCLG live Table 100 reports, from April 2009 onwards, the total dwelling estimates and their tenure breakdown down to LA level (grouped according to type of authority, not to region).

Owner occupied and private rented sectors reported at the LA level are subsumed into one private sector category. At the national level LA and PR sub-tenures are separately reported.

MHCLG Table 104 provides a historical annual dwelling stock series, dating back to 1801, with a tenure breakdown first provided in the census year 1961 and then annually from 1969 onwards.

The short story it tells is that in 1961 the LA and the private rented (PR) stock when combined exceeded the then c6.1m dwelling owner-occupied stock.

The LA stock continued to climb to its 5.2m peak in 1980, after which it plummeted to its current trough level of less than 1.6m. compared to about 2.6m RP owned dwellings, when, until 2008 there were more LA-owned than RP dwellings.

The PRS stock slid from 4.4m in 1961 to 1.6m in 1986, before subsequently recovering robustly to its current level of about 4.9m.

The owner-occupied dwelling stock progressively increased in total numbers throughout the period to its current c.16.3m dwellings, notwithstanding that its percentage tenure share fell from its recorded high of nearly 70% (69.5%) in 2001-2002 (EHS figures reported nearly 71%) to 64.5% in 2010-11, where it has broadly remained since.

Annex Table Two derived from MHCLG live Table 104 reports the total stock dwelling estimates, for each year since April 1991 up to 31 March 2023, by tenure and sub tenure.

MHCLG Table 109 provides a summary breakdown for the same post April 1991 period, by tenure and region.

Table 2 provides summary data for dwelling stock, by tenure and sub-tenure, as percentage of total for the census decadal years 2001, 2011, 2021, and then for 2023.

It reports that the owner-occupied tenure share fell from nearly 70% in 2011 to about 64% in 2021, while the percentage of the total dwelling stock taken by the private rented sector (PRS) nearly doubled as a percentage between 31 March 2001 from about 10% about 19% in 2023, with the share taken by LA rented more than halving from about 13% to about six per cent during the same period, with the RP tenure share rising to about 10%.

Since 2001, the combined LA and HA total (labelled social and affordable rented in the table) fell from about 20% to about 16%.

The EHS reports that since 2013-14 outright owners have outnumbered mortgagors 35% of households reported in 2022-23 as owning outright compared to 29% as mortgagors in 2022-23, a product of an aging population leading to larger numbers of people paying off their mortgages and becoming outright owners, as well as probably of an increased unquantified number of cash purchasers.  

Table 2A reproduces Table 3 of the MHCLG 2024 dwelling stock statistical release, which presented and reported an increase in the combined LA and RP tenure stock (labelled as ‘social and affordable rented’) of c25,000 dwellings in 2022-23.

Since April 2009, according to that official table, their combined total has increased on average annually by about 14,000 dwellings (disregarding dwellings categorised as ‘other public sector’).

That table, however, made no split between Social Rented and Affordable Rent’ sub-tenures let up to 80% of market levels – a significant omission insofar that many commentators consider the affordable housing sub-tenure not to be ‘genuinely affordable’.

Annex Table Three, reports the annual change by numbers in the estimated dwelling stock for each year since April 1991 up to 31 March 2023, by tenure and sub tenure, withLA and RP figures split.

It reports a continuing decline in the LA rented stock, which since April 1991 has fallen by more than 2.3m dwellings, compared to an increase of around two million in the HA stock.

The primary driver for that outcome is the impact of Right-to-Buy (RTB), introduced as a new flagship social policy by Mrs Thatcher in 1979 and statutorily enacted in the 1980 Housing Act.

MHCLG Table 678 reports that during the 40-year period from the introduction of the Right-to-Buy (RTB), starting in 1981 and ending 2022, more than two million dwellings were sold to LA and RP tenants exercising their RTB, c93% of which were to sitting LA tenants.

Such annual combined RTB sales peaked at c84,000 in 2003-04, before collapsing to c.3,100 (mainly because of changes in discount and eligibility arrangements) in 2009-10, before rising to a more stable average of 13,200 dwellings across the 2013-22 period. 11,303 dwellings were sold to sitting tenants in 2022-23.

The fluctuating RTB stock losses, summarised in Table 2B, contributed to the results reported inAnnex Table Three.

These tables, when taken together, show that the LA lost nearly 100,000 dwellings annually during the eighties, reducing to 45,000, on average, during the nineties, and to 35,000 in the noughties, and further still to about 10,000 annually during 2010-20 and the most recent 2018-23 half decade.

Although the outflow from RTB has decelerated, since 1991 the LA net stock has still lost a net c2.3m dwellings.

During 2022-23, there were 11,200 RTBs in the LA sector, 4,600 RP sales to sitting tenants, a total of 15,800 sales to social housing (LA+RP) sitting tenants.

Summary and policy implications

The dwelling stock series is a core series calibrated to the past decadal census then to the new supply series until the next census.

It conveys more information than is generally recognised on tenure composition trends, derived from an additional range of sources, including the English Housing Survey.  

Annex Table Three, itself derived from series table 104, in contrast to Table 2A, breaksdown net changes to dwelling stock to sub-tenure, including renting from local authorities, confirming that it lost about a further 5,000 dwellings in 2022-23, despite an uptick in new builds and, by the standards of 1981-2006 at least, a relatively modest level of about 11,000 RTBs, and provides a good indicator, albeit measured at a lagged stock rather than flow level, of net changes in tenure composition.

The new Labour government is expected to trim RTB discounts but given its fiscal rules will forbid increases in net current expenditure that add to debt (in case, say, a revenue contribution to new council provision, financed by RTB proceeds), it will need to navigate a trade-off between future RTB volumes and receipts generated that could be recycled into new investment.  

That 35% of households reported in the 2022-23 EHS as owning outright compared to 29% as mortgagors in 2022-23, clearly has implications for economic and social policy beyond housing, insofar that it can be expected to reduce the effectiveness of interest rate changes on house prices and broader macro-economic outcomes, as well entrench generational inequalities.

More granular and assessable information of sub-tenures, including Build to Rent (BTR), and Buy to Let (BTL) would be helpful.

Quite clearly, however, the most pressing and important policy issue or implication is the growing concentration of poorer, younger people into the PRS, often poorer quality stock in locations offering limited economic opportunities.  

3          Affordable housing series

Introduction and definitions

The affordable housing series reports the gross annual new supply of additional affordable dwellings for rent or sale that is provided for specified eligible households whose needs are not met by the market.

Dwellings classified and recorded as affordable housing, according to the official definition, encompass a range of sub-tenures. These are defined briefly below.

Social Rent (SR) dwelling rents are set according to national guidelines involving the calculation of a ‘formula rent’ for each property based on its relative local market value, on relative local income levels, and on its size.

This is done with reference to a stated aim to ensure that “similar rents are charged for similar properties” that is not always realised in practice.

Dwellings let in accordance with such arrangements are termed Social Rent (with initial block capitals) dwellings in this post.

The MHCLG in its January 2024 MHCLG Social housing-lettings April-2022 to March-2023 (Tenancies) statistical release advised that the national median SR in 2023 was 47% of market rental levels, although that proportion can vary within and between areas and regions.

Another sub-tenure akin to SR, as explained here, is London Affordable Rent, calibrated to 2016 Social Rent levels, save that the annual rental increase allowed for SR lets was back then capped until April 2020 at Consumer Price Index (CPI) less one per cent (CPI-one per cent), but LAR rents could be updated annually by CPI inflation plus one per cent.

Since April 2020 CPI + one per cent been the base ‘social rent’ cap set for all SR and AR tenancies let by LA’s and RPs, as set out in this 2020 government statement, save where subject to an overarching ‘cost of living’ cap.

In this post, data on LAR delivery is subsumed within the SR category.

Affordable Rented (AR) housing was introduced in 2011 by the incoming Coalition government to be let by providers of social housing to eligible households at a rent of no more than 80% of the local market rent (including service charges, where applicable).

According to the above same MHCLG release, it was let at a median 71% of market rent levels in 2023-23.

Intermediate Rent (IR), according to official definitions, should not exceed 80% of the current market rate – although some exceptions to that rule may be included and recorded in the affordable series data.

SR + AR + IR is officially defined as ‘social rented’ or ‘low-cost rental’ housing (no capitals), and thus is wider in sub-tenure scope than the Social Rent (with capitals) sub-tenure, as defined above.

That can prove confusing, especially when SR and AR are not specifically differentiated in the data.

Accordingly, for the purposes of this post, what is officially defined as ‘social rented’, is generally described as Social Rent (SR) and Affordable Rent (AR) and Intermediate Rent (IR) combined, or as is applicable.  

Intermediate affordable housing are homes for sale and rent (not SR or AR) provided at a user cost above Social Rent levels but below market levels, subject to it remaining at an affordable price for future eligible households and/or to the recycling of expended subsidy into the support of alternative affordable housing provision.

Such housing can include shared ownership and other tenure forms where some equity is retained by the provider, as well as other low-cost homes provided either for sale or for intermediate rent.

In 2021-22, First Homes was created as a sub-tenure form intended to eventually account for at least 25% of all affordable housing units delivered through planning obligations but was embraced by LA’s generally with reluctance.

Its future following the 2024 General Election result is uncertain and it could possibly be replaced with an alternative government-sponsored home ownership product.  

The new Communities and Housing Secretary in her July 2024 announcement confirmed that LA’s would not be required to provide a prescribed proportion of affordable home ownership housing and emphasised a refocus on SR provision.

Dwellings purchased under the post-2013 Help-to-Buy programmes are not recorded as affordable housing, on the ground that purchaser access was not subject to an income qualification.

Social landlords of what is officially defined as affordable housing can be a local authority (LA) – letting dwellings generally known as council housing – or be a private registered provider (RP) registered with the Regulator of Social Housing (RSH).

Historically, only non-profit-making organisations, previously known as housing associations, and still sometimes referred to as such given that most private registered providers are HAs, (this post will also use the terms HA and RP interchangeably), could be registered as providers of social housing or as social housing landlords.

Since April 2010 profit-making organisations also have been able to register with the RSH.

RPs can now include:

  • organisations providing supported housing and care;
  • local authority subsidiary companies;
  • community groups seeking to develop new housing;
  • commercial developers setting up small subsidiaries to receive Section 106 affordable housing;
  • subsidiaries of investment companies and funds;
  • entities established by registered provider groups, either new parents for their group structures or new subsidiaries;
  • small charities, such as alms houses.

Dwellings provided by non-registered providers should not be counted as affordable housing. However, in practice, they sometimes are (they are, for instance, separately defined in MHCLG Table 1013, see below).

Affordable housing can be newly built, acquired, or result from a net gain secured through conversion or from a change in use.

The affordable housing seriesreport Gross totals that take no account of demolitions (representing a direct dwelling loss) or of sales of existing affordable dwellings overwhelmingly into owner occupation.

The series, therefore, does not report changes in annual net affordable supply: the net flow of stock gains minus losses across each sub-tenure – which can be positive or negative – nor its availability, as indicated by new lets.

Rather, it measures new affordable provision activity (predominantly of new build, but also including acquisitions and net gains or losses from conversions and from changes in use).

Such gross new provision of sub tenures therefore influences, but does not necessarily determine, either their net stock position – which Annex Table Three reported in the preceding section acting as a p[atrial corrective – or their letting supply availability, as Section Four will shortly show.

Affordable housing series data

Affordable starts and completions for the preceding financial year (2022-23) are published in the succeeding late November/early December (2023) alongside updated live tables, which are also subject to scheduled revisions each June/July.

MHCLG Table 1000 reports the most up-to-date summary estimates of affordable housing provided for the period since the series started in 1991-92 (primarily new build completions, but also acquisitions and net additions resulting from conversion or from change in use).

Henceforth affordable housing series terms ‘completions’ and ‘provided’ are used interchangeably, unless otherwise stated

MHCLG Table 1000C additionally breaks down that summary data to sub-tenure by type of scheme and funding. Table 1000S reports also affordable starts on a similar basis but – as across the series in cases where starts are reported – from 2015-16 onwards only.

MHCLG Tables 1008C and 1008S break down the total affordable completion and start information to region and LA district level, while Tables 1006 and 1007 do likewise for different defined sub-tenure types, reporting both starts and completions.

MHCLG Table 1009 breaks the total affordable completion data down, according to whether the provided dwellings were newly built or acquired, by sub-tenure.

MHCLG Tables 1011C and 1011S report from 1991-92 onwards, affordable total completions and starts (from 2015-16), according to type and source of funding (including nil grant S106).

A dropdown box at the top of these tables allows users to access data at region and LA level.

MHCLG Table 1012 reports affordable housing starts and completions, funded by Homes England, combined with data with the GLA from April 2012, both for starts and completions, between 2009-10 to 2023-24.

The latest Homes England  and GLA dedicated affordable supply data for 2023-24 can be accessed via the aforementioned links.

Homes England and GLA are focused on the delivery of dwellings subject to their programme funding support.

The MHCLG affordable housing series has a wider remit to provide a complete picture on affordable housing delivered, irrespective of funding mechanism or its source, using more disparate sources, most notably LA annual housing statistical (LAHS) returns.

LAs are asked to only record affordable housing that has not been reported by Homes England or the GLA.

This should predominately be affordable housing that did not receive grant funding or developer contributions under planning agreements.

However, Homes England has confirmed that some nil grant S106s are indeed included in its data returns, and it is possible that some LAs double count by including them also in their LAHS returns

As their 2023-24 start and completion data are published in the following June, rather than in December, as is the case with the MHCLG series, these  two Homes England and GLA are utilised in a summary table in the scan forwards sub-section that follows.

New MHCLG Table 1013 breaks down affordable provided completions, by type of provider, whether LA, or registered, or non-registered providers, or unknown.

It advised that RPs provided 49,844 of all the 63,605 affordable dwellings recorded for 2022-23, compared to LAs that provided 8,906, with non-registered providers accounting for 2,273. Another 2,582 dwellings were classified as of unknown sub-tenure.

Of the LA provided affordable dwellings, 60% were let at Social Rent or London Affordable Rent (LAR) levels (3,926 SR plus 1,419 LAR: 5,345 in total): the highest figure since the series started in 1991-92, but still only 8.4% of the total affordable supply provided in 2022-23.

Annex Table Four summarises affordable completion data across the entire 1991-92 to 2022-23 series period, taken from MHCLG Tables 1009 and 1011C, broken down to sub-tenure.

The 63,600 new affordable homes provided in England in 2022-23 is the highest reported since 2014-15 and a seven per cent increase on 2021-22.

Gross annual total or all affordable provision across the most recent April 2018-23 period averaged about 58,000 dwellings, representing the highest level recorded since April 2007-11.

It coincided with the end of the 2016-23 Affordable Homes Programme, as did the earlier 2014-25 uptick peak with the end of the 2011-15 Affordable Homes Programme: funding programme approval and delivery profiles result in years where starts and completions are bunched.

Although the latest peak was considerably above the April 1999-2003 low point average of 33,500, it still fell short of the 68,200 annual average dwellings provided during the April 1992-96 entire series peak point period.

Although Table Annex Four appears to report relatively stable total affordable provision totals on a decadal average basis, in practice they could fluctuate quite sharply within each decade in response to programme profile issues, to funding availability, and to wider economic conditions.

Total new build affordable completions increased progressively decade to decade in total and as a share of all affordable completions as acquisition and conversion provision decreased (subject to the compositional issues discussed below).

The table also reports that since 2001, annual affordable new supply has accounted for a stable close to 27% share of total net new housing supply as reported in MHCLG Table 120 (see Annex Table One).  

But as Annex Table Four also shows, that share increased sharply in the wake of economic downturns (when private speculative activity contracts).

This it did across the post-GFC 2010-13 period when it rose above 40%, as affordable dwellings funded by a relatively previous generous affordable programme settlement were completed during a period when private completions were at record low levels as a lagged impact of the GFC.

The share tends to decrease, albeit less sharply, during upswing periods marked by private sector recovery. This it did during 2002-06 and 2015-17 periods to a share of 24% or below.  

Taking account of the compositional mix

The sub tenure composition of provided affordable housing has changed markedly since the mid-nineties.

As Annex Table Four, summarised in Table 3, shows, the predominance of dwellings let at Social Rent (SR) levels started to decline from 1997-98 onwards.

56,900 Social Rent dwellings were provided in 1996-97 – greater than two and half times of the 21,700 SR completions reported in 2004-2005, and four times the 13,900 dwellings (including LAR) provided in 2022-23 – the most since 2012-13.

While the sub tenure still provided 82% of all affordable dwellings in 1999-2000, its share had declined to 57% by 2009-10.

This was  a combined product of falling SR volumes and the rising intermediate sub tenure completions that accounted for the remaining share of the programme, to about 42%.

The share taken by SR then collapsed to 14% in 2014-15, although most affordable dwellings were let at Social Rents until 2012-13.

This was the result of the introduction by the 2010-15 coalition government of the Affordable Rent (AF) sub tenure and the associated diversion of public grant funding in support of AR provision, which that year provided 62% of total affordable dwellings.

Intermediate tenures accounted for the remaining 24%. Their volume had decreased from 24,800 in 2009-10 to 15,800 in 2014-15 before dipping further to 9,300 in 2015-16.

Since 2014-15, shared ownership (part owned, part rented) homes have provided about a third of all affordable housing supply, becoming the predominant affordable home ownership sub-tenure.

Overall, all affordable home ownership sub tenure types since 2018-19 have accounted for the same 35% to 38% proportion of all affordable dwellings that it did twenty years ago.

During the latest 2018-23 period nearly three quarters (74%) of the average annual 36,100 combined social and affordable rent completions total were let at higher Affordable Rental levels, with SR providing an average 9,700 dwellings compared to 26,400 AR completions. Intermediate tenures provided an average 16,400 dwellings annually.

SR volume recently increased in 2022-23 to nearly 14,000 dwellings, enlarging its sub tenure share (including LAR) to 22%. By then AR’s share of affordable completions had fallen slowly but progressively to 38%, totalling 24,300 dwellings.

These compositional changes in the affordable housing programme concerning the volume and tenure share shift away from SR in favour of AF, as was identified above – as well as possibly other potential ones not reported or highlighted here, including changes in the bedroom composition of the provided dwellings and/or their location – provide a salutary example of the care needed to interpret time-series data on a consistent like-for-like basis.

Here, to take account of, and to statistically adjust for the shift away from SR provision towards government Affordable Rent (AR) housing provision, Table 3A  has applied the following weightings: Social Rent = 1; Government Affordable Rent = 0.625; Other Intermediate = 0.5.

When these are applied, the 2011-21 decadal average annual completion figure compared to that of previous 2001-11 period, total affordable completions transpose from around nine per cent higher to around nine per cent lower.

The most recent 2018-23 annual average affordable completion figure is also greatly reduced from about 27% higher than the 2001-11 average to about one per cent higher.  

Tweaks to the weightings applied would vary that outcome.

Table 3A also shows that, disregarding programme and other cyclical variations – and after adjusting for the compositional effects identified above – gross affordable supply when measured on a cross-decadal average basis has proved broadly stable in total volume terms.

Total affordable completions on an average annual decadal basis, weighted as above, reduced from 36,900 during 2001-11 to 33,700 during the following decade. The most recent 2018-23, half decadal average was slightly higher at 37,300.

Such apparent relative long-term stability of affordable housing supply, of course, is a different issue as to whether gross affordable supply in volume and compositional terms was – and is – sufficient and/or well-targeted relative to prevailing and changing socio-economic circumstances and needs.

These can include demographics, wider housing supply and its composition, and its affordability relative to individual household income and other circumstances rather than official definition.

And, as will be shown in the following Section Four, new gross affordable supply crucially also does not necessarily equate with new housing letting opportunities.

The paramountcy of S106 nil grant to new affordable supply

Annex Table Five uses MHCLG Table 1011C to estimate the number and proportion of all completed affordable dwellings using Section 106 (S106) affordable housing obligations to deliver affordable housing without the use of public grant both in total and by sub tenure.

Such affordable dwellings are generally secured through the planning system through developer cross subsidies realised from sales of dwellings sold at market values.

This table identifies a general trend since the nineties – save for some trend interruption in the wake of the Global Financial Crisis (GFC) – for the proportion of affordable housing across tenures provided through S106 to progressively increase

This is to a point where S106 nil grant has become the primary reported funding mechanism of affordable housing.

They exceeded 50% of total affordable completions in 2019-20, and 47% of them in the latest reported 2022-23 year.

The story of how S106 became the primary funding mechanism of affordable housing is recounted in Section 1 of  The new infrastructure levy: going-round the mulberry bush.

In terms of sub tenure composition, nil grant S106, in general, delivers a greater proportion of intermediate tenure properties – about 53% in 2022-23 – than Social Rent (SR), where it delivered about 38%.

As ever, averages can mask variation. In London, only four of the 1,567 dwellings provided through conventional Social Rent (excluding London Affordable Rent) was provided though nil grant S106, although S106 nil grant did account for 39% of the London Affordable Rent dwellings provided.

Scanning forwards

Affordable starts for the April 2018-23 period by sub-tenure (when known) reported in MHCLG Table 1011S, provide an indication of future short-term gross affordable completion levels.

About 71,800 affordable starts were recorded in 2022-23. Annual average starts recorded during the 2018-23 period was 61,000 dwellings.

Unfortunately, it is likely that this figure over the 2023-25 period will fall back to below 50,000 dwellings.

The most recent data on affordable starts and completed funded by Homes England and the GLA, summarised in Table 3B, shows that in total, starts fell to about 31,000  in 2023-24 from 55,000 dwellings in 2022-23. In London they plummeted even more dramatically by about 90% to about 2,300.

The precise reasons for this sudden and apparently calamitous drop are not totally clear or, at least, accepted by competing stakeholders, but programme profile and approval issues, market conditions and costs, and the impact of post Grenfell and other regulatory requirements all seem to have played a part.

Public funded start data reported as funded by Homes England and the GLA can be expected to fall short of what will be reported in the more comprehensive MHCLG Table 1011S in December, for reasons explained earlier.

The 55,100 affordable starts reported by Homes England and the GLA for 2022-23 accounted for about three quarters of the 71,800 total later reported in Table 1011S.

Conducting a rough rule of thumb exercise, replicating that relationship would suggest about 42,000 starts in 2023-24. The December reported figure could, of course, be lower or higher than that, but the omens overall are to the downside.

Such a level in practice would require affordable starts to increase to about 58,000 in 2024-25 to get to an 2023-25 annual average of 50,000 dwellings, and a similar completions level projected forward into 2026-28.

Summary and possible policy implications

This section has reported a feast of data on affordable housing produced by MHCLG. So much, in fact, that it is easy to be overwhelmed by detail, missing the wood for the trees.

It is therefore probably sensible to summarise the main points or contours of the story.

First, the series does not purport to report changes in annual net affordable supply: the net flow of stock gains (predominately now new build provision, but also acquisitions, conversions etc) minus losses mainly from RTB and other sales and to a lessening extent demolitions) across each affordable sub-tenure.

That net supply flow can be either positive or negative (see Annex Table Three).

Nor does it measure affordable housing availability, as indicated by new lets (see Section Four and its accompanying tables).

Second, broadly speaking, contrary to the political heat and noise and spin often put on comparisons between periods generally bookended by changes in government and/or cherry picked to outlier peak or trough years, over successive medium term 1991-21 decadal periods total average affordable housing completions remained relatively stable within a 46,000 and 52,000 range.

Shorter-term gyrations linked to affordable housing programme approval and funding profiles, as well as to wider public expenditure funding choices occurring over comprehensive spending review cycles (see Annex Table Four) also feature.   

Example of the former was 2015-16, and of the latter, the squeeze on the affordable housing programme during the early noughties as result of the decision of New Labour to stick to the previous government’s spending programmes and to prioritise other areas of social spending.

Third, there have been, however, significant compositional changes, most notably in the secular volume and share decline of Social Rent (SR) provision, within the programme.

Average annual SR provision fell progressively from about 41,000 dwellings in the 1991-2000 decadal period, to 27,700 the following decade, to under 12,000 in the 2011-21 period.

Until 2011 that was largely a combined product of declining grant funding support of affordable housing and a shift to intermediate tenures within the programme.

The decision by the 2010-15 Coalition government then to further reduce and shift government funding support to affordable rent (AR), let at closer to 80% rather than  the closer to 50% market rental levels that SR is let at, meant that by mid-decade the proportion of the programme taken by that new sub tenure began to exceed 50%, before starting to drop back from 2019-20 onwards towards 38% (see Table 3).

Most affordable dwellings provided before the mid noughties were let at Social Rents; during the latest 2018-23 period, nearly three quarters (74%) of the average annual 35,800 combined social and affordable rent completions total were let at higher AR levels.

Fourth, even when such compositional changes are taken account of and adjusted for, as this section did (recognising that results could change if different weightings were applied), affordable dwelling provision since 2001 appears stable on a cross decadal comparison basis (see Table 3A).

The shift to AR allowed more output, officially defined as affordable, to be squeezed from a given level of resources. This, however, was at the cost of higher rents, higher housing benefit costs, worse affordability at a household level, and of heightened risk of pushing more families into poverty after housing costs, even though the rationale lent to its introduction included that AF would improve such metrics if it allowed households to move out of temporary accommodation or the PRS.

Shifting back to SR, however, will involve higher levels of grant support, which given the new government’s fiscal stance, may not be forthcoming, in which case such a shift could involve SR taking a continuing rising proportion of a stable or even a reduced total affordable provision total, while most poor households remained in the PRS.

Efficiencies such as moving to longer-term funding settlements and the targeting of funding support to the areas most in need of affordable housing, such as London, could help to weaken but not lift such trade-offs over time.

Since 2014-15, shared ownership (part owned, part rented) homes have provided about a third of all affordable housing supply, becoming the predominant affordable home ownership sub-tenure.

Overall, all affordable home ownership sub tenure types since 2018-19 have accounted for the same 35% to 38% proportion of all affordable dwellings that it did twenty years ago.

Fifth, a general trend since the nineties – save for some trend interruption in the wake of the Global Financial Crisis (GFC) – is for the proportion of affordable housing across tenures provided through S106 affordable housing obligation process to progressively increase from negligible levels in the nineties and noughties to become the primary reported funding mechanism of affordable housing, accounting for 47% of affordable completions in the latest reported 2022-23 year.

This provision route, in a sense, represented a privatisation of public housing investment into affordable housing (as did the stock transfer in the late eighties and nineties) allowing this time a portion of increased land values to be captured for affordable housing purposes.

In the absence of substantial increases in direct public grant support, this now established provision mechanism will need to continue to do much of the heavy lifting to support affordable housing provision, even though recent market conditions and cost pressures could reduce the scope for such a cross-subsidy mechanism, in the short term, if developer expected profit margins are not to suffer.

Longer term, increased delivery through this route in the absence of wider strategic reform of a private speculative housing business model predicated on profit rather than output maximisation within a market with multiple failures, will rely on higher house prices with attendant affordability and access problems.  

Sixth, the overarching message is that since the nineties both Labour and Conservative governments have struggled to maintain affordable supply, especially of SR, due to increased fiscal pressures and a political unwillingness to prioritise housing relative to other spending programmes and/or tax cuts.

This is unlikely to change with the Starmer government. Although its fiscal rules will allow borrowing for investment, its commitment for public debt to reduce as a proportion of gdp (total economic output) by the end of the new parliament could cause problems and even prove self-defeating, given the potential capacity of increased affordable housing to contribute to growth generation.

Since 2001, annual affordable new supply has accounted for about 27% of total annual new net additions (supply) on a decadal average basis (see Annex Table Four).

For the new government’s commitment to deliver 1.5m new homes by 2029 to be achieved that share will need to increase substantially (see section five for a more detailed analysis).

There is simply little or no prospect of private speculative annual completions reaching the 200,000 to 250,000 dwelling level (250,000 + 50,000 affordable = 300,000; 200,000+100,000=300,000; the more realistic private speculative maximum of 180,000, would require an affordable gross provision annual level of 120,000 dwellings).

The view of this website is that such a step change requires a recasting of both public and delivery systems where the provision of a variegated range of affordable housing sub-tenures is mainstreamed within both, but that is another story.

4          Social Housing Lettings

Data and some commentary reported in this section is taken from the MHCLG January 2024 Social housing-lettings April-2022 to March-2023 (Tenancies) statistical release (January 2024 MHCLGsocial lettings release), unless otherwise stated.

Again, definitions can be confusing. The release describes ‘social rented’ housing as that let at sub-market rentals including Social Rent (SR), Affordable Rent (AR), and Intermediate rent (IR) sub-tenures (see definitions set out in Section 3).

The distinction between new lettings and new first lets to tenants not previously social tenants, should be understood.

New lettings are the combined total of first lets of newly built or acquired properties and reletsof existing properties.

13% of new lets in 2022/23 were in properties that were let for the first time as social housing. The majority of these were new builds (11.5%) with the remainder being made up of new leases (0.5%) and conversions, acquisitions and rehabilitations (0.8%).

87% of new lettings were relets of existing social housing (overwhelmingly LA+RP) stock.

Total social sector (LA+RP) new lettings represent new housing opportunities to both their existing tenants and to households offered and accepting a letting new to the sector, including those coming from temporary accommodation (TA) and/or statutorily homeless.

Around a third (32%) of households starting a new social tenancy in 2022-23 were existing social tenants renewing or transferring within the sector – the remaining 68% entered from outside the sector.

New first lets to tenants not previously social tenants, while they can be the first lettings of newly built or acquired properties or be a relet of an existing property, are those made to households not previously social tenants – whether they formerly resided in the PRS or in other tenures, shared with others, or were in temporary accommodation or otherwise homeless or otherwise were not existing social housing tenants.

51% of total new Affordable Rent lettings were first let in 2022-23, compared to 38% of new Intermediate Rent lets, whereas only five per cent of new Social Rent lets were first lets in contrast to being relet.

SR, however, has remained the primary sub-tenure of the existing social housing stock, explaining why, notwithstanding the secular trend shift towards Affordable Rent (AR) since 2011, 83% of total new social housing (SR+LR+IR) lettings (including relets), 209,190 dwellings, were let at Social Rent levels in 2022-23.

AR accounted for the remaining about 17% of the 2022-23 total new lettings total, compared to 13% in 2015-16. In 2012-13 soon after the sub tenure was introduced, it accounted for seven per cent of total new sub-market lettings.

Intermediate Rent (IR) accounted for a negligible one per cent of total 2022-23 lettings.

The 20 largest social housing providers (in terms of total new and relets) provided 27% of total lets. Of these 20, only one was a local authority (Leeds City Council).

The top three largest PRP providers were Riverside Housing Group, Anchor Hanover and Sanctuary Housing Association, providing in total 16,000 new lettings or 6% of all new lettings in 2022/23.

Since 2007/08 the share of total new lettings provided by local authorities has fallen from 40% to their current 29% share.

PRPs in 2022/23 provided 71% of total 2022-23 social housing (LA+RP) lettings; LAs the remaining 29%.

75% of total new lettings were for General Needs (GN) and 25% were Supported Housing (SH) lettings.

SH is housing provided with special design facilities or features targeted at a specific client group requiring support, for example housing designed for older people or those with disabilities.

38% of GN lettings in 2022/23 were one-bedroom properties or bedsits; 41% had two bedrooms, 19% had three bedrooms, and two per cent had four or more bedrooms.

New letting opportunities and churn rates

Total LA new lets including relets, averaged over 400,000 between 1981-2000,  according to MHCLG Live Table 602, sourced from Local Authority Housing Statistics (LAHS) data.

Their churn rate (percentage of properties let as proportion of stock) increased during the nineties to reach a record 12.3% in 1996-97. That year nearly 417,000 LA dwellings were let, higher than around the 379,000 that were let in 1989-90 and the 404,000 in 1981-82.

Social Rent LA lettings thus held up well during most of the last two decades of the twentieth century despite the massive net loss of stock from the RTB that marked that period.

But, as Table 4 (also derived from MHCLG live table 602) charts, total LA new lets had fallen to about 327,000 by 2000-01 and then continued to calamitously collapse to about 80,000 in 2021-22, before experiencing a small uptick to about 87,000 total lets (including mutual exchanges and short-term lets) in latest reported year 2022/23.

In parallel their churn rate also continuously reduced from 2000 onwards, save for flatlining between 2007 and 2014, halving from 11.5% in 2000-01 to 5.5% in 2022-23.

Instructively, Table 4 also records that LA new lettings to households not previously living in a social housing dwelling plummeted to about 55,000 by 2022-23: less than a quarter of their 2000-01 level.

As discussed later, a secular trend related to the recent ballooning numbers of households in local authority provided and largely funded temporary accommodation (TA).

Neither MHCLG Table 602 nor Table 4 report RP lettings, which are not are not tracked by a consistent long term national time series.

However, the Continuous REcording of Lettings in Social Housing in England (CORE) series does provide data, using a different collection methodology to the LAHS.

It is a ‘flow’ measure of all new social housing lettings recording data at case level (i.e. individual lettings), whereas data in LAHS is a ‘stock’ measure of all social housing stock in local authorities. 

CORE also excludes mutual exchange, short-term and some other lets. Other classificatory changes, in addition, mean that comparisons over time should be made with caution.

Although CORE is designed to be a complete census of new social housing lettings provided by local authorities and private registered providers that own social housing stock, the provision of local landlord information is voluntary. Some LAs do not respond, necessitating a weighted imputation process to be undertaken by CORE using LAHS data.

Further detail and explanation can be found in the MHCLG technical notes that accompany the latest 2022-3 social housing lettings statistical release.

These differences at least partly explain why the LA lettings figures and the relet (churn) rate that Table Four report are higher than the CORE levels reported in Tables 4A and 4B, derived from CORE April 2022-23 social housing lettings data (tenancies, summary table), which includes a compendium of data tables reporting a massive range of tenancy information, some of which is disaggregated to LA and RP landlord level.

Table 4A reports trends in the numbers or volume of all lettings by RPs and LAs (including general needs and supported housing let at SR and AR levels) during the 20011-23 period.

In short, total social sector lets fell from 394,500 in 2011-12 to 251,900 in 2022-23.

It also charts a secular trend reduction in the LA relet or churn rate, similar to what Table 4 reported for all LA lettings between 2011-12 and 2022-23 (7.5% falling to 4.6% compared to 8.3% falling to 5.5% in Table 4). RP lettings as proportion of RP stock also fell from 11.2% in 2011-12 to 6.8% in 2022-23.

Table 4B drills down on general needs tenancies, separating SR and AR lets across LA and RP sub tenures, confirming that their combined lets of SR and AR general needs tenancies dropped from 252,000 in 2007-08 to 182,900 in 2022-23 (the 2020-21 figure of 166,500 was likely a Covid-related outlier).

Total RP lettings including for both general and supported housing needs across all tenancy types fell from 267,200 in 2011/12 to 179,300 in 2022-23 across England.

As Figure 7 of the January 2024 MHCLG social lettings statistical release shows graphically, this was despite the RP stock increasing in net numbers whilst new LA lettings have fallen by more than LA stock did.

Reduced churn relet rates and the secular falling letting trend are a linked feature of both sub tenures.

Declining social housing churn or relet rates in isolation, or in combination, could be attributed to:

  • a widening affordability gap between social and market rents;
  • previous and continuing net stock losses (a RTB cannot be relet)
  • an intensifying inability or unwillingness of social tenants to exit the tenure due to their persistent and unchanging disadvantaged labour market and their other socio-economic characteristics;
  • changing tenancy age structure profiles;
  • longer void turnaround times;
  • allocation policies; or
  • other unidentified factors.

The MHCLG in its January 2024 social lettings statistical release, pointed out that generally a higher proportion of stock was relet (churned) in northern England than it did in the south: 7.1% of the combined social stock (LA + RP) in the North East region was relet during 2022/23, compared to 2.3% for London.

It went on to suggest a trend connection with regionally varying social rented (SR + AR) levels and local market affordability.

Figure 24 of the same release graphically represented median (mid-point) weekly rents (£) by rent type, between 2007/08 – 2022/23, across England, indicating a median market rental rent of about £200 in 2022/23 compared to about £180 for AR and about £130 for SR.

Such figures, however, will be influenced by the generally higher churn (relet rate) of social sector rental properties in northern and midland areas. Such properties are let at relatively low rents across those areas compared to high-cost areas, such as London that exbibit low churn. This is another example of a compositional effect.

Figure 26 of the same release plotted the average rent for new social lets (lets at sub-market rents, not just SRs) as a proportion of market rent by local authority area, for 2022/23. They ranged between 25% and 80% of market rentals at the extremes.

Although linking regional rental variances to churn rates accords with common sense observation, supported by any passing acquaintance with the London’s prevailing house prices and market rental levels (recognising their variation within the capital) –(see section six).

Yet the data and current evidence is insufficient to delineate and to definitively quantify separately all the contributory causes of both declining churn rates and letting volumes.

Statutory homeless acceptances

Definitions and interpretations of the homelessness legislation is largely taken from the government’s Homelessness Code of Guidance, unless other stated.

Homeless households found to be eligible for assistance, who are unintentionally homeless and fall within a priority need group (responsibility for dependent children, pregnant women, people over retirement age and others deemed vulnerable, as well as those facing an emergency, such as fire and flood) are owed a main statutory homelessness duty under Part Seven of the 1996 Housing Act by the local housing authority that they have a ‘local connection’ with.

The Homelessness Reduction Act (HRA 2017) further focused on preventing individual and family homelessness through the introduction of new prevention and relief duties. All applicants now are entitled to a minimum 56 days of assistance under the prevention and relief duties, prior to a main duty assessment and decision.

A prevention duty is now owed to applicants threatened with homelessness within 56 days, including when a Section 21 eviction notice (ending an assured shorthold tenancy) has been served which expires within that period, including the provision of advice and assistance.

It applies regardless of priority need status, intentionality or local connection, but generally will not cover applicants subject to immigration control (see chapter seven of the guidance for detail).

To discharge the duty, LAs are required to “take reasonable steps to help prevent any eligible person who is threatened with homelessness from becoming homeless… either (by) helping them to stay in their current accommodation or helping them to find a new place to live before they become actually homeless” (para 14).

The prevention duty continues for 56 days unless it is ended by an event, such as accommodation being secured for the person, or by their becoming homeless.

The relief duty applies where the applicant is or becomes or already is homeless, despite prevention stage intervention. It requires responsible LAs “to take reasonable steps” to relieve an applicant’s homelessness, focused on helping the applicant to secure accommodation available and suitable for their occupation, for a period of at least six months.

Where the housing authority has reason to believe a homeless applicant may be eligible for assistance and possesses a priority need, they must be provided with such interim accommodation (para 15).

The relief duty also lasts for 56 days, by which time the applicant should be provided with a decision as to whether they are owed a main homelessness duty or not, although if it is yet to decide on whether the applicant is in priority need and/or intentionally homeless and there is reason to believe that the applicant is in priority need, the interim accommodation duty owed under the relief duty continues until a decision is made on the main housing duty.

If no main home homelessness duty is owed the responsible LA possesses no further homelessness duties for the applicant.

During calendar year 2023, the relief duty ended for 63,650 households of which:

17,860 were secured accommodation in supported hostel or housing, 17,220 in the PRS, 11,860 in RP accommodation, 7,160 secured a council tenancy, while 3,710 stayed with friends and family (Table R2, homelessness statistics, see link below).

A responsible local authority owes an applicant, who is homeless, in priority need, and not intentionally homeless, a main homelessness duty under the 1996 Housing Act, as set out at the beginning of this sub-section.

That definition was not changed by the 2017 HRA. However, such applicants are now only owed a main duty if homelessness was not prevented during the preventative and relief duty stages and where they fall within the priority need categories (set out in more detail below) and are not intentionally homeless (paras 16 and 17).

Certain categories of household have priority need if homeless, such as pregnant women, families with children, and those who are homeless because of they are a victim of domestic abuse or due to an emergency such as a fire or flood.

Other groups may be assessed as having priority need because they are vulnerable because of old age, mental ill health, physical disability, or having been in prison or care or because of becoming homeless due to violence.

When determining whether an applicant in any of the categories set out above is vulnerable as defined under the homelessness legislation, the responsible LA should determine whether, if homeless, the applicant “would be significantly more vulnerable than an ordinary person would be if they became homeless”.

The main duty requires responsible LAs to provide temporary accommodation until the duty is discharged.

Usually this will be through the offer of a settled home (whether accepted or refused by the applicant), which could be suitable secure or introductory tenancy with a local authority, an offer of accommodation through a private registered provider (also known as a housing association) or a suitable tenancy for at least 12 months from a private landlord made by arrangement with the local authority.

The duty can also be discharged by the LA providing advice and assistance that is sufficient to secure an offer of such secure accommodation that is reasonable and suitable given the applicant’s circumstances. 

It will also end for the responsible authority where the applicant turns down a suitable offer of temporary accommodation, abandons or loses it, or otherwise ceases to be eligible.

Alternatively, it may be possible for the applicant to be ‘homeless at home’, where, for example, an unsustainable family or sharing arrangement is extended on the basis that alternative secure and suitable accommodation will be made available in the future.

During calendar year 2023, the main duty was ended for 43,020 households. Three quarters – 31, 530 – accepted a social tenancy (Part Six 1996 Housing Act social housing offer). 2,860 accepted an offer of PRS accommodation (Table MD2, homelessness statistics).

The MHCLG homelessness statistics collection includes a range of data tables on reasons why applicants became homeless, their circumstances, and actions taken under each of the homelessness duties.

Information at a local LA level can also be obtained from MHCLG detailed local authority tables at a quarterly level and for financial year 2022-23, as well as from its data dashboards on homelessness  and rough sleeping, although this website found them tricky to navigate.

Table 4C reports statutory main duty homelessness acceptances from 1998-99 onwards, at an England level, using the MHCLG source collection.

Until 2004-2005, such acceptances (as then defined) exceeded 100,000 but then fell sharply to about 40,000 in 2009-10.

Subsequently acceptances then rose steadily to about 59,000 in 2016-17, before nearly halving to about 31,000 in 2018-19.

That year represents a discontinuity in the data as it marked the introduction of statutory prevention and relief duties enacted by the 2017 HRA.

Table 4C records that main duty acceptances have since returned to around the 60,000 level for 2023 calendar year (which is also the expected estimated figure for 2023-24).

Recourse to temporary accommodation

Annex Table Six records the numbers placed in temporary in accommodation (TA), by LAs further to their homelessness duties under the 1996 Housing Act and the 2017 HRA defined above.

By 1 January 2024, a record 112,600 households were in such accommodation: more than double than the close to 50,000 households placed during calendar years 2010 and 2011.

Indeed, after falling from 101,000 in 2004 (all dates refer to TA position at 31st December of the year cited) to 48,000 in 2009, numbers in TA have steadily since increased to their current level.

A July 2024 Audit Commission tackling homelessness report (NAO 2024 homelessness report) advised that the DLUHC (now MHCLG) had concluded that the government achieved the reduction between 2004 and 2010 “through a public commitment to halve the number of households, coupled with significant investment and proportionately higher Housing Benefit” (para. 1.23).

The current near 113,000 total encompasses:

  • 29,400 nightly paid self-contained private accommodation placements, including self-contained annexes to hotels with very basic cooking and washing facilities (compared to less than 6,000 between 2002 and 2014);
  • 26,700 in dwellings leased by the accepting LA and/or a RP (compared with more than 40,000 between 2004 and 2007);
  • 33,400 put in temporary accommodation outside their home LA area – more than three times the levels that was recorded between 2003 and 2012;
  • 16,000 were in hotel bed and breakfast accommodation, even though in 2003 such accommodation was prohibited for households responsible for dependent children except in an emergency, and then for no longer than six weeks.

Recourse to TA is uneven, and is concentrated, as one would expect, across high housing need/stress areas, most especially Greater London and Greater Manchester within the North West.

A 2022 Smith Institute study reported a worsening situation in the majority of London boroughs and in the City of Manchester, where the number of households per thousand households was found three times the England average (in volume more than the whole of Yorkshire & Humber) during 2021-22.

The problem was most acute it found in some London boroughs: in Newham it was 12 times more; Southwark, Redbridge six times; in Wandsworth and Westminster five times.

More up-to-date information is provided in Figure 7 of the NAO 2024 homelessness report, which whilst confirming that use of temporary accommodation is particularly concentrated in London and parts of the South East and North West, especially City of Manchester, shows that its use is also scattered across the country and is not confined to those areas.

That said, in last quarter 2023, according to the latest available official data, 63,240 of the total 112,600 households placed in temporary accommodation were in London: 56% of the England total.

Such outcomes can also be linked to declining LA and RP letting availability. Directly provided CORE data reports sharp falls in new lettings to households new to the social sector, falling from 240,700 in 2007-08 across England to 147,000 in 2022-23.

Table 4D documents an even more calamitous long-term fall across London. LA first lets to new social tenants (including those accepted as statutorily homeless) in London fell from 40,500 in 1996-97 to 13,700 in 2011-12, before falling a further 33% to a reported 8,500 by 2021-22.

According to that same GLA Housing in London 2023 source, RP lettings to new social housing tenants fell even more sharply (45%) across the 1996-2022 period from 9,300 to 5,000, even though – unlike the LA sector – the RP sector grew in net stock size during that period.

In total social sector (LA+RP) lets to households new to social housing in London fell from 49,800 in 1996-97 to 13,600 in 2021-22.

CORE data also advises that total social sector lettings in the capital to tenants new to the sector halved from 28,800 in 2012-13 to 14,400 in 2022-23.

Also, according to CORE information that Tables 4E and 4F reproduce, 7,500 combined lettings were made by LAs and RPs in London to households coming from TA or who were statutorily homeless in latest reported year 2022-23 (compared to about 73,000 nationally).

That flow of new lettings to households previously in TA or who were statutorily homeless undershot the 12,040 main duty homelessness acceptances recorded by London responsible authorities during 2022-23 (Table MD3, MHCLG homelessness statistics, detailed local authority statistics, 2022-23).

A gap that seems to provide the main reason why the use of TA is so concentrated in the capital.

International comparisons

A recent article by the authoritative Financial Times (FT) data analyst,  John Burn-Murdoch, noted that homelessness among OECD countries was worst in the UK, when measured by the total numbers, who in 2023 or later, were placed in temporary accommodation.

The UK exhibited a staggering rate of 50 per 10,000 households in temporary compared to about 30 in France, 25 in Germany, 20 in the United States (US), and six in Denmark.

It, however, exhibited a rate of less than one for rough sleeping (varies between the UK’s constituent countries and cities) in contrast to nearly five in Germany and eight in the US.

On the face of it, such statistics suggest relative UK institutional effectiveness relative to its international peers in responding to rough sleeping that obvious and stark manifestation of homelessness, amid the patent ineffectiveness of its overall housing system(s) in meeting general housing need.

It should be borne in mind, however, that the metrics involved will vary in definition, in interpretation, and in measurement methodology between countries, as will the social context in which rough sleeping, especially, takes place. 

The MHLCG Ending Rough Sleeping Data Framework, provides quarterly management information on five core indicators underpinning the four aims of the vision for ending rough sleeping: that it is prevented wherever possible, and where it does occur, it is rare, brief, and non-recurring.

In that light, 3,898 people sleeping rough were recorded on a single Autumn 2023 snapshot night, higher for the second year in a row, but lower than the peak of 4,751 previously recorded in 2017 (Para 2.11 of the NAO homelessness report).

Table 4.4 of Housing in London 2023 report advised that outreach teams recorded 1,614 people sleeping rough in London for the first time, in the second quarter of 2023, representing an increase of seven per cent on pre-lockdown figures.

Most new rough sleepers spent one night only sleeping rough, including during the height of lockdown, when emergency rough sleeper accommodation programmes run by the GLA and London boroughs helped to reduce the numbers of rough sleepers, particularly in early and mid-2020.

Summary and policy implications

Resource to temporary accommodation is not only disruptive and unsuitable for settled family life and for future social-economic advancement but is also costly in short term current public expenditure terms.

Figure 5 of the of the 2024 NAO homelessness report showed that in 2022-23 spending by English LAs on the use of temporary accommodation exceeded £1.6bn: more than double in real (inflation-adjusted) terms than it was in 2010-11.

Local authorities pay for temporary accommodation and reclaim the costs as a subsidy from Department of Works and Pensions (DWP). The Temporary Accommodation Subsidy that they then receive is based on Housing Benefit rules and the Local Allowance Rate (LHA) rate, not updated for long periods from January 2011.

As that central subsidy source has been in effect capped on welfare expenditure control grounds, it has not kept up with rising costs at the local TA coalface. The resulting deficits that LAs incur on TA accommodation have consequently swelled, piling on their financial pressures.

These, according to the same NAO report, given the share of their net budgets taken by TA costs, could soon drive some LAs into bankruptcy.  TA now costs London LAs £1bn per year with £332m of that falling on their own budgets.

The NAO report also pointed out that a significant portion of the centrally financed Homelessness Prevention Grant has been diverted to fund the provision of temporary accommodation, particularly in areas of poor affordability, rather than being spent on prevention work.

This is a classic case of Peter robbing Paul resulting from immediate pressures trumping longer term best value and delivery outcomes – a tendency that has become increasingly prevalent across welfare state provision.  

Such are the facts on the ground that the new chancellor, Rachel Reeves, when deciding public housing investment allocations in accord with set fiscal rules (in Labour’s case, borrowing for investment is allowed but its volume must be consistent with a reduced public debt/gdp ratio by 2029), will need to grapple with in her first 30 October 2024 budget and the subsequent 2025 Comprehensive Spending Review (CSR) process.

Targeting and increasing housing investment funds to the LAs with the highest TA bills, mainly in London, presents a strong investing now to save later case, a baton  picked up in a densely researched and argued New Economics Foundation (NEF) March 2024 Buying Back Better report.

After reviewing the GLA Right to Buy-back (RTBB) 2021-23 scheme, which saw around 1,300 homes bought by councils quicker and often more in accord with client requirements than they would have been if built or obtained through protracted developer affordable housing obligations, the report highlighted that its successor scheme, the Council Homes Acquisition Programme (CHAP) – contingent on sufficient central funding support and tweaks to Approved Development Programme (ADP) rules – could allow London councils to acquire 10,000 homes over the next ten years, or 1,000 annually.  

Such an outcome, the report estimates, would over the next two decades reduce their TA costs by £1.5bn, trim central government housing benefit subsidies by £340m, and generate additional indirect savings of £440m, including projected £39m short term HB savings. Prioritising TA acquisitions within such a programme would save £26m; prioritising general needs acquisitions £49m.

Annual government-wide savings from CHAP would, the report projected, outweigh annual costs including loan repayments after 16 years, when annual savings would begin to accumulate, further noting that if the housing benefit subsidy cap is uprated, greater savings to LAs would result (although central government HB expenditure would increase, all other things being equal).   

A 2022 Audit Commission Review of the AHP since 2015 had earlier revealed, using government research, that in London, future housing benefit savings over 30 years would cover the cost of 69 per cent of the grant cost of providing new homes for social rent, and that this would go up to 110 per cent over a 60 year period, leaving aside savings in temporary accommodation and social care costs.

One step back. Grant rates under CHAP are higher than were under the RTBB scheme, providing grants for up to £200,000 for each social rented home; and for £85,000 for each TA home acquired.

This spend now to save later approach is a microcosm of the wider argument that transferring PRS households receiving housing benefit (HB) to the social sector would accumulate savings in central revenue expenditure over time.

Lower SR rents would require less HB support, underpinning arguments for a SR programme approaching 100,000 new homes annually, as, to take one example, is argued here.

Expanding such funding would therefore be a call on constrained public investment resources with the financial return extended into the long term beyond the lifetime of two parliaments.

While the increased availability of local authority-owned accommodation let at SR rents could produce significant long-term savings for taxpayers via reduced housing support costs (whether centrally or locally funded), that is a hope rather than a certainty.

Future HB costs will depend on a range of future unknown as well as expected factors.

Political focus, on the other hand, is geared to the short to medium term, as are Labour’s fiscal rules: not 15 or 25 years, let along 30 or 60 years, unfortunately.

In truth, the prospect of an annual new SR centrally funded programme being scaled up to approach 100,000 dwellings by 2029 (five years ahead), even when supported by a more certain and robust developer contribution policy regime and helped by a reformed Compulsory Purchase Order (CPO) process effective in reducing land acquisition costs closer to existing use value, seems uncertain at best, and unlikely, probably.

This is, even though, as the next section will demonstrate, Labour’s flagship commitment to deliver 1.5m additional homes in this parliament will depend on – amongst other outcomes, such as expeditious and effective delivery of its New Town, urban extensions, and devolution ambitions – an expanded affordable homes programme rising to a sustainable 100,000-150,000 annual level, sooner rather than later.

As the 2022 Audit Commission report cited above highlighted, the existing regional distribution of AHP grant fails to reflect either the variations in need for investment in different parts of the country or the benefits that would flow from altering it.

The data reported in this section has also demonstrated the linkage between declining social sector lettings and rising recourse to TA, concentrated in London and other high need hotspots.

The case for adjusting the AHP as part of the 2025 CSR in favour of London and tilting it towards supporting additional social housing provision across such areas appears overwhelming on both housing need and expenditure efficiency grounds.

Likewise moving to a ten-year rather than a five-year AHP, as proposed in the 2020 Double or Quits  University College of London (UCL)  Bartlett School of Construction and Project Management  report, and subsequently by many  stakeholders, accompanied by other efficiency enhancing programme rule flexibilities, should allow potential supply volumes and efficiency to be increased, as well as help to smooth delivery over the duration of the programme, avoiding programme-end peaks.  

More broadly, greater attention on the lettings data reported and their implications seems justified and necessary. At the end of the day, it is the letting capacity and the flow of annual new lettings of social landlords that determines new housing opportunities for households in housing need.

Given the low churn rate in high cost and high need areas, especially London, the systematic routemap to maximise LA letting capacity through the development of letting chains that a former Southwark Council cabinet lead for housing, set out in another 2022 Smith Institute publication, appears pertinent.

Given RPs dominant sub-tenure and repository of public investment status and position, more transparent and topical information on the volume trend of LA nominations to RPs could also be helpful.  

5        New housebuilding, indicators of new supply, and final tenure estimates

The MHCLG in September 2020 changed the title of its “House building: new build dwellings’ statistical release to “Housing Supply: indicators of new supply”.

As the series live tables were predominately concerned with new build, this was a confusing change, in the view of this website, risking conflation with the “Housing supply: net additional dwellings” series covered in section one.

A recent quarterly published statistical release stated the purpose of the series is: “to provide an indication of the levels of and trends in new housing supply in England” advising that it should “be regarded as a leading indicator of overall housing supply”.

Section Four of the release continues to highlight the building control reported new build starts and completions data (termed in this post, the new housebuilding series), even though, as explained and demonstrated below, it covers 80% or less of house building activity in England and systematically undercounts new build activity.

Section Five of the release does, however, cover other indicators of housing supply, advising that along with the above they are intended (in totality) to “provide a suite of information which give a rounded estimate of the current trends in housing supply and an indication of what the more complete estimate of housing supply, net additional dwellings, will show when it becomes available in November 2024”.

New housebuilding series (MHCLG ‘new build dwelling’ figures based on building control inspection data): the live tables

MHCLG Table 213 covers both new build starts and completions, by tenure of the provider, both on an annual financial year (from 1969-70) and on a quarterly non-seasonally adjusted basis, (from quarter, Q1, 1978 to Q2 2023 at the time of writing, then updated by the quarterly reporting cycle).

It starkly reports that during 2023-24 only 134,780 new build dwellings were started (the lowest since 2013-14), 104,310 of which were reported as built by private enterprise (the lowest since 2012-13).

During the same period, 153,800 dwellings were completed, 115,780 of which were reported as built by private enterprise (both figures the lowest reported since 2015-16).  

MHCLG Table 222 provides similar but quarterly seasonally adjusted figures.

MHCLG Table 244 catalogues the longer-term new housebuilding record, broken down by tenure, on a calendar year basis, from 1946 onwards.

MHCLG Tables 217, 253 and 253a report dwellings completed and started by tenure, broken down to region (quarterly) since 1990-91 (217), LA district (253, by financial year, 252a, quarterly since 1980-81).

MHCLG Table 254 reports completions and starts, by house or flat type, by bedroom size, and by tenure. 

The Office of National Statistics (ONS) in its House building, UK: permanent dwellings started and completed by country statistical series also continues to publish new housebuilding data according to country, as well as at a pan Great Britain and UK levels. 

ONS tables relating to England replicate the live tables published by the MHCLG and are updated to incorporate revisions, unlike the annual statistical release commentaries.

New housebuilding series (MHCLG ‘new build dwelling’ figures based on building control inspection data): development, methodology and undercounting

The new housebuilding series began in 1946, sourced solely from LA building control information, considered the best source to identify when new build dwellings are started (specifically the commencement of construction in laying of foundations) and the timeliest measure of new build completions (as measured by the completion certificate).

However, such sources became increasingly fragmented. National House Building Council (NHBC) data was added from 1985 and then in 2007 independent approved inspectors also became a statutory source of data.

The MHCLG estimates that the building control sourced data source currently provides information on about 80% of house building in England.

In computing the series, MHCLG statisticians make allowances for non-response (reported as high as 78% for independent approved inspectors in Q1 2023). This done through a process of imputation from past returns to take account of late submissions.

The technical notes accompanying the series recognises, however, that late and non-reporting continues to prove a problem.

Indeed, both the MHCLG and ONS live tables under-enumerate recent new build completions, often by a large magnitude.

Annex Table Seven reports that the annual discrepancy (undercount) between the new completion totals reported in Table 213 of this series and the more accurate net supply Table 120 reached an annual average of about 24% across the most recent 2018-23, period, compared to an average of about 17% across the entire 2006-2023 period covered by Table 120.

This ONS new housebuilding series similarly consistently undercounts recent new build activity.

Reporting new housebuilding by tenure more accurately

The MHCLG interactive dashboard published with this series provides important new data on new build completions by final tenure, when occupied.

This is the final tenure usage of the new dwelling, whether for future private ownership, for housing association or for local authority housing use.

The final tenure use of a completed dwelling is not necessarily the same as the tenure of the developer that built it because private developers also build dwellings for housing associations and local authorities, as well as predominately for onward private sale.

Indeed, as was discussed in Section Three and documented in Annex Table Five, a progressively larger proportion of affordable dwellings since the early 1990 have been built by private developers in accordance with S106 planning agreements concerning affordable housing obligations.

Some, perhaps most, of these dwellings are reported and recorded as private enterprise completions within the new housebuilding series tables, even though they are later transferred or sold to RPs for future use within their stock.

Annex Table Eight reproduces tabulated information that can be accessed from the series dashboard’s final tenure estimates tab (see previous link), cataloguing new build completions from 2006, by final tenure.

It utilises the more accurate net supply (total new build completions) and the affordable housing series (LA and RP new build completions) from 2006 onwards – when the new build component in the net additional dwellings estimates was first published – to model and estimate more accurately private enterprise final tenure figures (Section 7of the statistical release describes in more detail).

Prior to 2006, the tenure of dwellings, by provider, is derived from building control sources, meaning that the table reproduces new housebuilding series data.

The table also conveys the cyclical sensitivity of private speculative new build activity to the wider economic environment.

Annual private enterprise completions more than halved from about 164,000 between 2006-8, the high-water mark of an era of low inflation, interest rates, and steady economic and household income growth, to less than 70,000 between 2009-12, as the lagged impact of the GFC played out.

During the 2006-23 period, LAs and RPs accounted for – on an average annual basis – about 26% of all new build completions, by final tenure.

That proportion varied, however, not only with the annual trend of new build affordable completions but also with that of private sector completions: their collapse in 2010-11 largely explains why the social sector share of all new completions rose to about 42%, by final tenure that year, as it took a growing share of a dwindling total (the denominator fell proportionately more than the increase in the numerator).

As way of contrast, social sector (LA+RP) annual new build completions fell to historic lows of between 13,000 to 14,500 dwellings – less than 10% of total new build completions during the 2000-2003 period: a result that reflected the lagged impact of early New Labour housing investment levels having been crimped by its self-imposed commitment to keep to the previous John Major government’s spending requirements, as well to the higher priority that New Labour accorded to other social programmes.

It was only towards the end of its period in office, when, in response to the 2004 Barker Report, social housing investment allocations were quite substantially increased, enabling some recovery in social housing new building activity, which subsequently partially blunted the impact of the GFC on total completions. 

Projecting 2023-24 new building completions and housing new supply

Both the Conservative and Labour parties during the 2024 general election committed to deliver at least 1.5 million new homes during the lifetime of the next parliament – equivalent to 300,000 new homes each calendar year, 2025-29 inclusive.

Putting that vaunted ambition into perspective, about 212,000 new builds were completed each year from April 2021 to March 2023, according to the most accurate MHCLG new additions (supply) series, while net new supply (including gains from net conversions, change of use, less demolitions, additional to the 212,000 new builds) hovered around 234,000 dwellings (see Annex Table One).

Concerning the expected 2023-24 outturn, Section Five of the MHCLG’s latest new indicators of housing supply release as discussed above, provided analysis of indicators other than building control new build data, including Energy Performance Certificates (EPS) lodged for new dwellings, building and council tax data.

Instructively, the release went on to advise that the EPC statistics provide a very close estimate or proxy to net additions, almost to the point of giving an official steer that are the most reliable indicator of future new supply.

At time of writing, however, such EPC data is relevant to the immediate past 2023-24 financial year to be reported in November 2024 – at least until sufficient 2024-25 EPC data is reported.

In that light, Table 5 compares the number of EPC of certificates lodged for new domestic properties (new build, conversions and change of use to domestic) with MHCLG Table 120 net new additions (new supply) across 2018-23 actual net new supply outturns.

It indicates that net supply on an annual average basis was 0.98 below the reported number of EPCs granted across that period (although, this was after a retrospective census adjustment was made for the 2018-21 new supply figures).

Applying that 0.98 coefficient to the reported 232,473 new dwelling EPCs reported lodged during 2023-24, suggestsa 2023-24 new net supply figure of about 227,000 dwellings, continuing its recent downward trend. 

Projecting future 2024-27 new build activity and new supply: implications for Labour’s 1.5m delivery target

MHCLG new housebuilding and other indicator of new supply series data, as customised in Tables 5A and 5B, strongly suggests that the recent downward new supply trend will not be reversed during the early 2024-26 period of the Starmer government.

MHCLG Table 213 data reproduced in Table 5A reports that 481,240 new build dwellings were started between 2021-24, an annual average of 160,400.

To compensate for the systemic tendency for new housebuilding series to undercount, as was laid out above, an adjustment multiplier of 1.24 was applied to the to the Table 213 starts and completion data reported in Tables 5A and 5B to produce adjusted figures.

That adjustment made was consistent with 2018-23 under-enumeration of Table 213 MHCLG Table 120 new build completions of about 24% that Annex Table Seven demonstrated for the 2018-23 period.

The average difference between Table 213 reported completion totals across 2018-23 and the later net new supply annual reported totals reported for that period was 41.5% and an adjustment coefficient of 1.415 was applied on Table 213 start and completion data to produce projected future new net supply figures

On that basis, Table 5B projects a 2024-25 and 2025-26 net new supply outturn (assuming a two year start to completion gestation) of about 244,000 and 191,000 dwellings, respectively (the reported adjusted new build 2022-24 start totals rolled forward two years as completions), suggesting a 2024-26 financial year net new supply total of about 435,000 dwellings; or an annual average of about 220,000 across those two years.

Such a level would generate a cumulative delivery shortfall of about 160,000 dwellings relative to the 300,000 annual target by April 2026.

Such rule of thumb projections are inherently tentative and indicative. Although yesterday starts are tomorrow’s completions, starts data provide a forward but imperfect indicator of future completions: they are subject to cyclical fluctuation related to the external economic and market environment and to funding programme profiles and associated delays.

New build completions, in practice, can also lag for longer than might be expected if a one-to-three-year construction period is assumed. Large scale regeneration projects involving multi-phases invariably straddle many years.

Lags could also possibly relate to incentives to record starts for programme monitoring purposes or result from other unquantified reasons.

In short, there is no way of knowing precisely when reported starts will be converted into a conversion.

Given the subdued nature of the private housing market in 2024 and the expected continuing impact of high (albeit hopefully further softening in line with the July 2024 0.25% base rate cut) interest rates, little reason currently exists that 2024-2026 completion totals will prove much different to the expected and projected weak 2023-24 outturn.

Indeed, as Section Three projected, a downtick in new affordable supply annual starts over the 2023-25 financial year period to an average 50,000 dwellings or less can be expected, suggesting a similar level of affordable completions during 2025-27.

Future affordable supply prospects beyond that are uncertain given its dependence on private cross-subsidy (less is available in a weak private market), the future impact direction of building and labour costs, and RP ability to use reserves to finance new building considering post-Grenfell and environmental regulatory requirements that require increased investments in existing properties.

In such an environment, increased grant funding needs to be made available to secure a future step change in affordable supply. Angela’s Rayner’s 30th July statement to parliament on that score was vague in terms of whether the forthcoming CSR housing settlement would involve substantial additional resources rather than a refocus of resources towards Social Rent (SR) provision.

Increased ADP resourcing would involve a time lag of least two years before it translated into new build completions, although acquisitions involving programmes such as CHAP (discussed in section four) could be quicker.  

The new Labour government also intends to introduce a revamped mortgage guarantee schemes for first time buyers in place of the retired Help-to-Buy (HtB) and to prioritise implementation of its pledge to ‘build rather than block’ planning reforms and compulsory purchase order (CPO) process reforms.

But planning reform by itself, while necessary, will not result in the current speculative private market-led system delivering future housing volumes on the scale required.

The outlook for completion outturns going into 2027 is not much brighter, therefore, on any realistic reckoning.

 Barratt, example, in July 2024 announced a seven per cut in planned starts for the coming year into 2025 that will then inevitably translate into future 2026 and 2027 completions.  

Research conducted earlier in the year by Savills included a chart that indicated – assuming no increase in government housing support – annual new build completions not breaking through 160,000 throughout the remainder of this decade, meaning that annual net new supply would undershoot 200,000 let alone reach 300,000 (less than 1m rather than 1.5m).

That doomsday scenario is unlikely to come to pass given Labour’s linkage of planning reform to its growth agenda, New Towns programme, and commitment to boost affordable housing supply, but the undoubted delivery shortfall projected above by 2026-27, supported by the work of other commentators, means that for the 1.5m  target to be achieved, supply would need to reach well beyond 300,000 during the 2027-30 period.

Even a 2024-27 (financial year as measured by MHCLG Table 120) cumulative new supply total of 750,000 or 250,000 annual average new supply across that period (on the current evidence, unlikely, as presented above, with undershooting much more likely), would require annual new supply delivery (let alone new builds) across the 2027-29 financial years to exceed 320,000 dwellings annually to achieve the 1.5m homes target (1.5m minus 750,000 = 750,000, which divided by two = 325,000).

This was something achieved last during the 1964-70 Wilson governments, and then not really, as it straddled a period when net supply was lower rather than higher than new build totals because of accompanying slum clearance demolition and redevelopment activity.

Starmer and Labour’s target presupposes that several New Towns and urban extensions, at least in substantial part, are planned, land acquired, prepared, approved, funded and completed by the end of 2029, amid a wider step increase in both private and public activity, measured by completions.

Angeal Rayner, herself, no doubt fortified by internal MHCLG briefings, intimated in her July parliamentary statement that supply would need to rise to 375,000 annually to compensate for early under-delivery.

Such outcomes, on the face of it, seems unrealistic, pure and simple.

Perhaps, a more realistic but still stretching target, requiring early concrete and effective policy action and reform, would have been to achieve 300,000 starts by 2026 calendar year on a future sustained basis.

Even that target would be tricky to measure, given the new housebuilding series (which measures quarterly without much time lag) related tendency to under count.

Indeed, the measurement problem where MHCLG table 213 new build starts and completions can be counted on a quarterly and annual basis but involve systemic undercounting, while the more accurate MHCLG table 120 new supply (net additions) table reports for financial years 18 months will, in any case, make the measurement of Labour’s flagship target, if not a fool’s errand, problematic, heavily exposed to political spin.  

Besides, because of construction lags and the overlapping impact of previous policies and conditions, a total production or supply target based on completions over the lifetime of a parliament didn’t and doesn’t make much sense, other than as a statement of political intent (hopefully) or spun aspiration (more usually).

Summary and policy implications

At a statistical reporting level, this website has previously recommended that MHCLG should advise users that the new housebuilding series should only really be used for two main reasons.

First, to consider longer-term trends related to the tenure breakdown of housing starts and completions, especially prior to April 2006.

Second, although the Housing supply: net additional dwellings series provides the best measure of new net supply and new housebuilding completions, it remains a lagged backward-looking metric that does not cover starts, requiring that recourse to the new housebuilding series as a leading but imperfect indicator of future near-term new build activity is necessary, complemented by other sources of evidence, where available and appropriate.

The new housebuilding series demonstrated tendency to undercount that, however, can be compensated for, as was done in this section, albeit on an imperfect rule of thumb basis, subject to phasing and contingent factors and uncertainties.  

The placing and enforcement by the MHCLG of more effective statistical collection and reporting requirements relating to housing starts and completions, although administratively challenging, would relieve the problem at source.

More importantly, scenarios based on the evidence currently available and considered in this section, point to a conclusion that the new government could possibly struggle to deliver over one million, let alone one and a half million, additional homes during the next 2024-29 parliament.

Even approaching Labour’s lifetime parliament target of 1.5m homes will require many New Towns and/or urban extensions to be identified, planned, authorised, funded, and at least partially completed within five years (something that would not necessarily show up in official statistics at the earliest in November 2030, probably more than a year after the next election).

Such a feat would require sustained political overarching focus and institutional coordination and drive of a nature unprecedented and unexperienced for decades.

It would also require public pump-priming infrastructure investment mid-decade rather than end-decade, enabled by a firm but flexible, rather than ironclad, interpretation of fiscal rules, focused on sustainable growth and best use of public resources over the medium term rather than mechanical and rigid calculations of future debt levels.

A focused, co-ordinated, streamlined and effective public-private partnership approach to housing delivery on lines suggested by the 2017 Letwin report, yet going further, in line with an overarching and primary political commitment to achieve a step change in housing, especially affordable, delivery accounting for a much larger than the current 27% share of total delivery.

These are preconditions but are not guarantors of the achievement or near achievement off the 1.5m target in practice rather than rhetoric.

The Starmer government in its July 2024 proposed planning reforms demonstrated its intent to remove blockages connected to local Nimbyism and other planning-related obstacles.

However, setting local delivery targets consistent with an annual supply level of 375,000 is not the same as securing their actual delivery on the ground. Councils do not currently build dwellings at scale (other than a few homes built for rent within the Housing Revenue Account (HRA)): developers do.  

Achieving such an elevated target, requires not only sufficient planning permissions but their implementation by profit-maximising private developers, whose current business model requires them to rather build and release dwellings for sale in step with that imperative, not government targets.

6          House Prices, Rents, Affordability and Access

This final section examines house price, rental, and affordability data, explaining their differences between the different sources available and their related uncertainties, complexities and limitations.

2022-23 English Household Survey (EHS) data is also utilised and reported to provide relevant information on household tenure and housing affordability circumstances

House prices: the different indices

Getting a handle on house price outcomes and trends is tricky. Several different sources often reported in the media use different data and methodologies covering different points in the home purchasing process, which vary in coverage.

For example, Rightmove use asking prices. Lender sources, such as Nationwide and Halifax, use their own mortgage approvals data. The UK House Price Index (UK HPI) published by the ONS uses mainly Land Registry data produced at the end of the conveyancing process and reports transacted prices.

The ONS explains the various house price index measures and their strengths and limitations in their publication Comparing house price indices in the UK.

This points out that although Rightmove’s index, which is based on advertised asking prices is the timeliest offering a leading indicator of future sale prices, properties may not ultimately sell and complete at their advertised prices, resulting in consequent inaccuracy.

Nationwide and Halifax indices are based on their own mortgage approvals, which means that they also can publish quickly. However not all approvals lead to a transaction; moreover, individual lender approvals are not necessarily representative of all approvals; even more seriously, these indices do not include the 30% to 40% of transactions that are cash purchases. These indices, therefore, may provide a biased estimate of actual sale prices.

The ONS series and the LSL Acadata series are the least timely as they use transaction (registration of the sale in the Land Registry) data at the end of the conveyance process, published usually around two months after the latest period reported.

These series are not, therefore, forward-looking and tend to be of less interest to the media when hungry for a timely and catching headline and for forecasters wishing to project or predict future trends; they are, however,more complete in ultimately capturing the set of actual transacted properties during the period that they report.

The average prices that UK HPI reports are a (weighted) geometric mean and by excluding the inflating impact of a few highly priced properties the UK HPI measure aligns reported mean (average) prices closer to median (midpoint values)

This in contrast to the simple average that the ONS quarterly house price tables, based on a on a sub-sample of the Regulated Mortgage Survey, report.

Figure 2 of the ONS guide cited above, which compared the average price time series for the various indexes, indicates that the UK HPI reported values, are as much as 25% lower than those reported by the LSL Acadata and Rightmove series. The same divergence is discernible between it and the ONS’s own quarterly series.

The UK HPI series is also a mix-adjusted index, which means that it is weighted to reflect annual changes in the mix and other attributes of the properties transacted.

The period with the base period for its price series is updated every five years, when the whole price series is rescaled to align with the new base period. Halifax also update their weights annually, while the Nationwide index updates its weights every two years.

To put it simply, mix adjusted indexes aim to report changes in average prices that take account of the changing composition of its source data of registered transacted dwellings, screening out possible distortions associated with outlier transactions, such that may arise with the sale, say, of highly valued properties.

The UK House Price Index (UKHPI) publishes UK HPI average house price estimates, associated indices and percentage growth rates down to regional and local authority level, according to property type, to buyer status (first time or former occupier), and to funding and property status (new build or existing).

The series thus offers greater granularity than do the other house price indices. Because it is based on all completed sales (rather than advertised or approved), including and cash and mortgage-financed purchases, it better reflects true house price trends, but with a backward-looking publishing lag.

National real house price trend since 1980

Annex Table Nine provides a time series between 1970 and 2024 for mix adjusted house prices across England, according to type of property, derived from that UK HPI series.

This table also offers a conversion of those cash prices into real (inflation-adjusted) terms.

A warning: the conversion of cash into real prices can be sensitive to the choice of deflator. Reported outcomes could differ if another conversion deflator was applied, such as the Retail Price Index, while, as explained above, the reported cash prices can vary substantially depending on the methodology and coverage of the index used.

Accordingly – as the case generally with house price indices – regard should be paid to trend variation rather than precise yearly figures conveyed.

Taking that on board, the main contours of the English house price story since 1980 can be broadly summarised thus.

  1. House prices in real terms were stable between 1980 and 1985, increased sharply between 1985 and 1990, before falling in both nominal and real terms between 1990 and 1996 – a period bookended at the start by a sharp recession in the early nineties that led to record levels of repossessions and negative equity; and at the end by the ushering-in of a period of low inflation, higher growth, and rising household incomes – sometimes called the Great Moderation.  
  2. By 2007, real prices had increased by a factor of between two and three. Cash or nominal prices during the 2000-2005 period exhibited an average annual percentage inflation increase of about 14% when annual inflation was around two per cent.
  3. The came the Great Financial Crash (GFC). House prices fell sharply in cash and real terms in 2008-2009, before recovering slowly in real terms by April 2014.
  4. Prices then the rose sharply again during 2015-2018, and 2020-22, before falling back slightly in real terms during the 2022-24 period, responding to rising interest rates and the cost-of-living crisis.  

Given the compilation and methodological issues briefly discussed above, the overall trend direction, as broadly summarised, should be taken as a guide with the average price levels reported for any year its conversion into inflation-adjusted constant price as indicative rather than precisely accurate.

Even more crucially, snapshots of house prices at any time point very much vary between regions and often areas (and sub-areas) within regions.

Country and regional trends

Table 6  reports average prices across the countries of Great Britian and by English administrative region, according to buyer (first time or former occupier) and property status (new build or existing), recorded by the UKHPI for April 2024.

It reports an average house price paid for all property types (taken as a proxy for all buyers) buyers in England of about £298,000 (nearest thousand), £158,000 for the North East, £203,000 in Yorkshire and Humberside, £375,000 in the South East, and £502,000 in London; £229,000 and £208,000 for Scotland and Wales, respectively.

With respect to the average price paid by first time buyers, it reported £250,000 for England, £136,000 for the North East, £175,000 for Yorkshire and Humberside, £299,000 for the South East, and £435,000 for London, and £153,000 and £180,000 for Scotland and Wales, respectively.    

Recent July 2024 data on lower quartile price non mix adjusted data also published by the ONS by indicates that in England that was £190,000, with lower quartile prices (price at the 25th point of the price distribution) ranging between £104,000 in the North East to £397,000 in London.

Table 6 also reports data on average prices paid for new and existing properties. The average reported new build price in England was £420,000 compared to £293,000 for an existing dwelling.

This new build premium of over a third appears surprising. This reported outcome is likely to relate to the compositional mix of new builds, and the tendency that they tend to be bigger in size and more likely to be detached at least in some regions (not London).

Such considerations underscore the need to treat headline house price data with caution, commensurate to the purpose of the inquiry.

The ONS provides an interactive guide to track average (estimated reported) house prices at the LA level in March 2024 (at time of writing, June 2024), by type of property.

A House of Commons Library dashboard, does so by single parliamentary constituency to neighbourhood level. It reports the non-mix adjusted median price paid for properties during the preceding twelve months on a rolling three monthly time series basis with latest reported at (at June 2024) for September 2023.  

Private rental levels

The primary source is the ONS’s private rental summary statistics series. This reports monthly rental prices for the private rental market in England according to bedroom category, by region and LA administrative area, calculated mainly from the Valuation Office Agency (VOA) data.

The ONS warns that that its source “samples are not statistical” and they should not be used to compare figures over time and between areas; nor do they include housing benefit (HB) claimants: a glaring omission insofar that 24% of PRS tenants according to the 2022-23 EHS were in receipt of HB.

The series reports lower quartile (the datapoint splitting the lowest 25% of rents from the highest 75%), the median (midpoint rent), and upper quartile (the datapoint splitting the highest 25% from lowest 75%), as well as recorded mean rent figures, for non-self-contained ‘room’, one bedroomed, two, three, and four bedroomed dwellings, for England, by region, across the 1 October 2022 to September 2023 period.

It is reproduced in Tables 6A to 6C for ‘rooms’ (bedsit-type accommodation as defined in note 1), one, and for three bedroomed dwellings.

The recorded median monthly rents for one bedroomed properties over that period for England, the North-East, the South East, and for London was £750, £450, £850, and £1,400, respectively.

For family sized three bedroomed dwellings, it was, £925, £600, £1,300, and £1,950, respectively.

These figures should be taken as a rough snapshot guide for the period in question.

They, of course, will also vary with area and neighbourhood; nor are they quality adjusted.  

Affordability and access (owner-occupation)

Another ONS dataset, using house price statistics for small areas (HPSSAs) derived from Land Registry recorded transactions, provides time series information on median house prices, earnings, and the median house price to median gross annual residence-based earnings affordability ratio, all by country and region (tables 1a to 1c),  by county (tables 3a to 3c), and by LA district (tables 5a to 5c).

Table 1c reports that the median house price to median gross annual residence-based earnings affordability ratio rose from 5.11 in England and 6.9 in London in 2002 to 9.06 and 13.62, respectively, in 2021, before subsequently slightly falling back in 2022 and 2023 as house prices dipped in response to increased mortgage rates.

The same ratio calibrated to the July 2024 ONS lower quartile series reporting the ratio of lower quartile house prices to lower quartile residence-based earnings, indicated a ratio in September 2023 of 7.25 in England, ranging from 4.32 in the North East,  to 13.1 in London, and 10.23 in the South East.

Such data does not report the affordability ratio for households who possessed sufficient savings or other resources (increasingly bequests) and income to purchase, nor the actual mortgage repayments of such households relative to their incomes, nor does it record properties sold at less than full market value.

They, accordingly, provide an indicator of the direction of affordability over time, but little about individual circumstances and access to home ownership for households with different circumstances, other than undoubtedly it has become much more expensive in general to purchase, relative to individual earnings.

Another House of Commons library (HOC) datasource using the ONS house price statistics for small areas series (HPSSA), reports house prices in each parliamentary constituency and the house price to earnings ratio.

It compares the median house price in each constituency (three-year 2020-22 average) with the median salary for full-time employees living there in each parliamentary constituency.

Fourteen London constituencies record a median house affordability ratio of more than fifteen. At the other end of the scale, eight constituencies report a median house affordability ratio of less than four, including Burnley, Copeland, Liverpool Walton, and Easington in England, and Blaenau Gwent, Rhondda, Aberavon, and Cynon Valley, in Wales.

As was earlier explained, the UK HPI is weighted to reflect the mix of properties sold in the previous year to make it broadly representative of the mix of properties in the overall dwelling stock.

The HPSSA, unlike the UKHPI, however, is not mix-adjusted, but uses rolling years to better reflect the actual mix of property sold.

As the UK HPI provides a measure of the changing market value of properties in the housing market whereas the HPSSAs measure the price paid for properties sold in each period, the two sets of statistics provide different figures, albeit exhibiting a similar time trend.

Unfortunately, the HPSSA series has been discontinued by the ONS and the final data available is for September 2022.

Another problem with all these measures is that earnings data is an incomplete measure of income, not taking account that many households have multiple earners, nor for the impact of other sources of income, such as benefits. At a local level, small sample sizes may aggravate variances.

Actual affordability ratios based on house price and mortgage advances data,  such as Table 44a of the 2024 UK Housing Finance Review,  reporting mortgage cost-to-income ratios for first-time buyers to the country/region level, indicate that the average ratio in England was 19.5% in 2022, while across its most expensive areas, including London and the South East, it registered between 20 and 21%.

The problem with such series – the converse to the one inherent with overall price to affordability ratios reported in the ONS datasets cited above – is that they only capture households that have been able to access and purchase through a mortgage a home, not those who were unable to access due to deposit requirements and/or unaffordable repayments whether by their own or lender decision.

The housing costs and affordability chapter of the 2022-23 EHS reported that the average (mean) deposit of a first time buyer in 2022-23 was £50,051 (£30,000 median), with 58% of such buyers coming from the top two income quintiles.

This piece of information helps to explain why 47% households in 2021-22 led by someone aged 25-34 were homeowners, less than the 59% recorded in 2003-4.

In 2021-22, 36% of purchasers reported receiving help from family or friends, while 9% used an inheritance as a source of deposit, a significant increase on the 22% of first-time buyers who reported help from family and friends in 2003-04.

89% of mortgagors reported in 2022-23 that they found it “very or fairly easy” to afford their mortgage, compared to 93% of mortgagors in 2021-22, with the proportion finding it “very easy” fell from 48% to 37%.  

However, an increased proportion of respondents reported a rise in some level of difficulty in affording repayments, with 9% of mortgagers finding it “fairly difficult” and 1% finding it “very difficult”.

The ONS has highlighted that monthly repayments on newly issued mortgages increased significantly recently in line with rising interest rates, noting that 1.4 million households in the UK faced the prospect of interest rate increases when they renewed their fixed rate mortgages in 2023.

Its map based affordability calculator indicates that purchasing a semi-detached property in the UK at the average December 2022 price of £286,000 would involve a monthly mortgage repayment of £1,262, assuming a mortgage term of 25 years: a £481 (61%) increase compared with the corresponding monthly repayment estimate in December 2021.

Purchasing the average detached UK property on the same terms in December 2022 would have resulted in a monthly mortgage repayment of £2,041 (up by 60.7% on December 2021).

For terraced houses, it would have been £1,063 (up by 59.6%). For flats and maisonettes, it would have been £1,028 (up by 54.6%).

In December 2021, a loan-to-value rate of 75% and a budget of £1,000 per month would have enabled a purchaser to afford an average semi-detached property in nearly two-thirds of local authorities in Great Britain.

With the same budget just one year later in December 2022, however, the same purchaser would have been able to afford the average semi-detached property in less than a third (30.1%) of areas.

Annex Table Two of the 2022-23 EHS, reported mortgage/rent as a proportion of household income for mortgagors and renters, resident for at least three years in 2022-23. 

That EHS table did not include housing-related costs, such as water and fuel bills, insurance, maintenance costs and council tax, were not included in that calculation. Income was taken to be the gross weekly household income with separate tables including and excluding benefits. Outright owners were excluded.

Two ratios were offered: one based on the household income (i.e. the income of all the members of the household, who are assumed to contribute to the mortgage); and the other based on the Household Reference Person (HRP) and their partner income only.

Between 2012-13 and 2022-23, the proportion of household income that mortgagors on average spent on their mortgage remained similar (19% in 2012-13 and 18.7% in 2022-23, according to the HRP plus partner measure).

Access and affordability: renters

According to the 2022-23 EHS, 59% (2.4 million households) of social renters and 24% (1.1 million households) of private renters received housing support (HB or the housing element of Universal Credit) to help with the payment of their rent.

A seminal June 2023 Institute of Fiscal Studies(IFS) study on renter housing quality and-affordability for lower-income-households reported that low-income households are increasingly private renters, renting relatively low-quality homes.

Younger low-income individuals today are more likely to privately rent than did older generations at the same age.

According to the same study, as at 2023Q1, just five per cent of private rental properties were affordable for housing benefit recipients.

Such properties were also more likely to have an energy rating of D or below, and on average have 19% higher heating and hot water costs. More generally they are more likely to be in low-employment and high-crime areas.

Moreover, most such tenancies are likely to be insecure and to suffer from quality issues. 

A 40% gross earnings rental affordability ratio, or more pertinently a 30% disposable income (including benefits) ratio may well push households further in poverty or into poverty, depending on individual household circumstances.

In that light, Annex Table Two of the 2022-23 EHS reported that for private tenants the average rental affordability was 40% (including housing support) and 46% (excluding housing support) relative to HRP plus partner income and for housing association tenants 30% and 38%, respectively (to nearest percentage points).

Although the 2023 Autumn Statement confirmed that Local Housing Allowance (LHA) will increase in April 2024 after having been frozen for long periods since January 2011, returning its coverage up to 30th percentile rent level, according to bedroom size, applicable to the local market area, making 30% of the market theoretically affordable to those reliant on housing benefit.

However, a recent Savills analysis of over one million Zoopla asking rents in 2023 showed that across Britain only 8.5% of such new listings would have been affordable using the new LHA rates.

The HoC datasource, using the ONS private rental summary statistics series, reports monthly private rents for two bedroomed homes, expressed as a proportion of monthly earnings, by LA area, for 2021-22.

Over 30 LAs, concentrated in London, reported a renter affordability ratio greater than 30.

Tables 6D-F  drills down on the ONS private rental summary statistics series.

It calculates monthly/annual gross incomes consistent with an arbitrary 40% affordability benchmark relative to room, one bedroomed and three bedroomed lower quartile rents, by region.

That an annual gross income according to that yardstick was required in London of £19,500, £35,100 and £49,500, respectively, for the period ending September 2022, suggests that the problem of affordability endemic for low-income households in the capital is both concentrated and endemic.

A more up-to-date and forward looking source is an ONS ‘statistics in development’ dataset on new renter affordability.

This estimates the proportion of actual gross earnings taken by rent paid by individual renters, starting new tenancies during the reported months up to May 2024, excluding guarantors, or individuals with very low incomes who are likely supported by another income source or whom have very high incomes that could skew the results.

The ONS advises that these reported estimates “reflect affordability at snapshots in time and are therefore not precisely comparable over time although the large sample size, covering around 30% to 40% of all rentals in the UK, ensures that the time series is useful”.

In May 2024, the proportion was 28.2% that month compared with 25.2% in May 2021. That estimate was an average, which, as ever, will mask variations, some of which will involve individual renters paying a higher proportion. It will exclude potential renters ‘priced out’.   

Summary and policy implications

This section identified a range of issues relating to the reporting of house prices and their affordability measures. It advised that attention should focus on the broad direction of direction and its regional/area differentiation rather than on short term headlines and precise figures, which, are always averages, if not estimates.

The assessment of affordability is particularly problematic. One common yardstick is that the maximum rent or mortgage payment should not exceed a third of after-tax household income or 40% of pre-tax income, as was employed above.

Some measures include other housing costs, such as utility and heating costs; and others don’t, and sometimes exclude housing benefit (HB) claimants, and 40% or whatever of household income, however, defined, differs in impact with income.

A feature common to both buying with a mortgage and renting affordability metrics is that taken across the board is that they can suggest affordability.

That conclusion is bedevilled, however, by the reality of the ‘priced out’ generation and ballooning levels of homelessness, often linked to insecurity and lack of access to, and unaffordable rents prevailing in the PRS, relative to individual circumstances.

Those able to buy, and to a much lesser extent, to rent in the PRS, are, by definition, self-selecting, insofar that they have managed to surmount the hurdles to entry, whether through their individual household circumstances and/or increasingly through being able to access family financial support.

The clear ensuing implication that follows, of course, as is well known and incessantly advocated, is a greatly expanded supply of affordable housing, especially let at SR levels.  

True, but this website worries that this is unlikely to be achieved anytime soon for a range of reasons touched on throughout this post and is easy to proclaim rather than activate and that in the unbounded meantime more extensive, granular, and concerted measures are needed.

It also rather suggests a bifurcated housing system with SR catering for those unable to purchase and able to qualify for it, with the remaining majority left to access the private speculative market.

In the absence of wider strategic cross tenure reform, the housing double binds that so mark the English housing system will continue to get tighter.

To take just one salient example, any dependence by the new Labour government on the private sector to achieve its delivery target, presupposes rising house prices to deliver required profit incentives and to maintain S106 cross subsidies within a constrained fiscal environment.

But that outcome will itself undermine access and affordability, especially to those wishing to become homeowners but with moderate and less secure incomes, while bestowing continuing greater wealth (and ability to assist offspring with their purchases on established owners, especially in high value/need areas: a self-perpetuating process, entrenching societal inequalities.

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Filed Under: Housing Tagged With: housing, housing supply, lettings, statistics

The CMA Housebuilding Study: Labour’s blueprint?

31st March 2024 by newtjoh

This extended post summarises and critically reviews the Housebuilding Market Study (the Study) that the Competition and Market Authority (CMA) published this February. This concluded that the housebuilding market in England, Scotland, and Wales is failing consumers and has consistently done so over successive decades, delivering outcomes falling well short of what a market working well should do.

Wider lessons are drawn from both the Study’s analysis and shortcomings to focus on the actions that a new Starmer-led United Kingdom (UK) government should put in hand within its first few weeks of office if it was serious in intent to achieve Labour’s proclaimed commitment to build 1.5m. additional homes during the lifetime of the next parliament in England (an average annual total of 300,000).

 Section One provides background to the process, defining the Study’s diagnosis of housing market failure taken from both the published final report and supporting evidence documents against the metrics of supply and affordability, the quality, innovation and sustainability of the delivered product, and the profitability of the 12 largest housebuilders.

Its main decisions on future actions, including the recommendations to government made concerning the future private management of public amenities on housing estates and on future consumer welfare, protection, and information outcomes are noted. Appendix A records those recommendations.

Section Two delves deeper into the causes and consequences of the wider market and the institutional failures that the Study identified, with reference to the operation of the planning system and the speculative housing model and its associated low build out rates.

The options it identified for government to consider while taking account of wider policy and other trade-offs, as well as other possible areas of government intervention that to improve outcomes across the planning and the speculative housing system and associated build out rates are discussed. Appendix B catalogues these options.

Section Three points out that the Study, like many housing policy commentaries, conveniently neglect the key political economy parameters of housing policy that need to be understood and addressed for real progress to occur.

These include the real fiscal crisis of the state, Nimbyism and related issues of local democratic preference versus the central compulsion required if set central government objectives are to be attained, lack of institutional capacity at both central and local levels, and political short-termism and the related lack of effective governmental focus on, or any real intent to achieve proclaimed objectives, most notably the overarching 300,000 supply target (the target).

Section Four points out that development timescales and almost certain substantial under-supply in 2025 mean that planning approvals and housing starts must begin their substantive upward trajectory no later than 2026 if the target is not to prove an early ‘dead duck’ or an example of ‘wishful verbiage’ for the new government, as it has proved for previous governments. It outlines an initial route map on how a new UK government could at least hit the ground running in its initial weeks in the light of that imperative.

It also demonstrates that the target cannot be achieved without a substantial step increase in the share of total supply taken by affordable and other forms of housing delivered outside the speculative model.

This – as will the enabling of New Towns and other large scale urban extensions – will require additional public investment. The 2025 Comprehensive Spending Review treatment of that investment requirement will thus provide an early and determining litmus test as of the practical application of Rachel Reeve’s fiscal rules and their positive relationship to wider macro-economic and strategic political goals.

1             Process and Diagnosis

The Competition and Markets Authority in February 2023 launched a Market Study (MS), under its Enterprise Act 2002 statutory powers, into the supply of new homes to consumers (‘housebuilding’) in England, Scotland, and Wales.

Under that Act, such a MS can be a self-standing piece of work or, where reasonable grounds for suspecting “that a feature or combination of features of a market or markets in the UK for goods or services prevents, restricts or distorts competition” are found, it can lead to a further market investigation reference (MIR), which can then culminate in the imposition of fines or other remedies on identified firms.

In November 2023 working papers on the  Private management of public amenities on housing estates, land banks, and the planning system(s). were published.

The  final report (the Study), alongside other supporting material including a supporting evidence document, was published on the 26 February 2024.  It concluded that intervention in the housing market was required for it to deliver better outcomes, across three main areas:

  1. More homes overall, and particularly in the areas of highest demand, in turn reducing pressure on affordability;
  2. Consistently better outcomes on new build quality, with consumers having an effective route to redress; and
  3. Reduced detriment to consumers arising from the private management of amenities on new build estates.

The CMA, however, decided against making MIR references regarding the existing private management of public amenities (estate management) or the land banking arrangements it had examined in detail.

With respect to estate management, it concluded that direct government action would provide a more appropriate and comprehensive response to the consumer detriment the Study identified as occurring, as well as its future prevention.

Specific policy recommendations (see Recommendations 1.1 to 1.5, Appendix A) were made aimed at preventing the future proliferation of private management arrangements on new housing estates and to provide greater protection to households living under such existing arrangements.

It further invited the United Kingdom, Scottish and Welsh governments (GB governments) to also consider options to support the adoption of public amenities on estates currently under such private arrangements.

The Study also made specific recommendations to governments to improve quality and redress routes for consumers and purchasers of newly built housing (Recommendations 2.1 to 2.6, Appendix A.

These specific recommendations were made across both the above areas, because better market outcomes could be obtained “within the current broad market framework and (they) which do not involve significant trade-offs with other policy objectives which are outside the scope of the CMA’s study and which would involve wider political choices”.

With respect to land banking, the Study found that their size and operation reflected wider market and institutional failures, namely the operation of the planning system and the speculative private housebuilding model alongside related incentives driving the speed of private speculative build out.

These wider failures, it concluded, would be better addressed through government action focused on those areas, (see section 2 below) rather than through remedial measures made specifically to reduce the size of landbanks, as these taken in isolation would most likely reduce housing supply.

However, on the back of evidence uncovered by the Study that suggested that some housebuilders may be sharing non-public information on sales prices, on incentives, and on rates of sale, the CMA did decide to launch an investigation under the Competition Act 1998 into such suspected conduct by Barratt, Bellway, Berkeley, Bloor Homes, Persimmon, Redrow, Taylor Wimpey, and Vistry, “given that it may have the object or effect of preventing, restricting or distorting competition”.

In March it announced that (outside the Study) it would commence a preliminary investigation into the proposed merger of Redrow and Barratt.

Supply and Affordability

The Study linked together two crucial facts that:

  • Housing supply has persistently fallen well short of successive government targets, “compounding over time to create a growing housing shortfall”; and,
  • Housebuilding has only previously reached the current 300,000 dwellings target (in England during periods where “significant supply was provided via local authority building”. Final report Figure 3.2 provides a useful annotated graphic illustrating that historically fundamental outcome.

The achievement of an additional annual supply of 300,000 is also the opposition’s target consistent with Labour’s commitment to build 1.5m homes over the lifetime of the next five-year parliament. The Welsh and Scottish governments have not hitherto set a headline total new supply target.

As Table 1, instructively, shows, the highest annual new supply (total net additions) figure recorded since 2006-07 (when the most accurate and comprehensive official housing statistical series to measure new completions and net additions in England began) was c248,500 dwellings in 2019-20: 83% of the 300,000 annual target; more pertinently, the annual average total supply across the entire 2006-23 period was c195,000 dwellings, c64% or less than two thirds of the proclaimed target.

The table also demonstrates the further substantive (albeit well known) point that the Study went on to make that new supply is also highly cyclical and prone to sharp fluctuation: the 2010-11 low point figure was barely half of the latest 2019-20 peak, as cited above.

Explaining this, the Study reported that most new homes are delivered through the private ‘speculative model’ of housebuilding for profit, where housebuilders buy land in advance of the construction and sale of homes without knowing the final price at which they will be sold.

Overall, according to the Study, around a half of GB homes are built speculatively, and a third on an affordable housing basis, sold or rented at a discount to market price; self- or other custom-built and build to rent completions account for the remainder of the total (noting that data on the tenure breakdown of completions is less accurate than total new supply data (DLUHC), certainly in the case of England.

In England, however, (less during market downswings, more during upswings) around 60% of new builds are produced through private speculative model. Scotland and Wales produce relatively more affordable housing, 45% and 50% of total new build supply in 2021-22, respectively, compared to around the 29% share that it takes across England.

The Study went on to highlight that this model produces too few houses, especially in the areas in which they are most needed, consequently, “exerting associated effects on local affordability and overall consumer welfare outcomes”.

“Significant variation in housing delivery relative to need” also occurs across both countries and regions, with Scotland in recent years coming closer to meeting its implied target levels than has England and Wales.

London, the South East, and the East regions (administratively defined) account for the majority of the areas exhibiting “significant under-delivery against assessed need”. All LPAs in the East of England, South East, South West, and London regions have an affordability ratio of five or higher.

Housing need is defined by the Study as “the amount of housing required for all households to live in accommodation that meets a certain prescribed standard (which irreducibly involves political judgement as to the acceptable standard)”.

This is a normative standard that invariably results in a higher figure than the 300,000 target. For instance, a 2019 Study (Bramley or Heriot-Watt Study) for the National Housing Federation (NHF) and Crisis found that around 340,000 new homes need to be supplied in England each year, of which 145,000 dwellings should be affordable.

A February 2024 Financial Times (FT) analysis  (not reported in the Study) that used the Heriot-Watt University methodology referenced above, but updated it with the latest (Office of National Statistics (ONS) population data and with net migration projections from Oxford University’s Migration Observatory, found that c421,000 additional homes were needed to be provided annually until 2036, assuming that average annual net migration to England figure will hover around 345,000 over the next 15 years.

On the other hand, the Study also cited an analysis (Study link broken, but summary by Ian Mulheirn can be found here) that argued that UK housing supply has outstripped household formation (for decades and that house price increases are a function of the main components of the cost of capital: mortgage interest rates, taxes, and expectations of future price growth.

Indeed, since the late 1990s, mortgage rates tumbled, with inflation-adjusted interest rates on five-year fixed-rate mortgages, for example, falling from 8% to around 2% which given that mortgage interest rates tend to be the dominant element of the cost of capital for homeowners, largely explaining the substantial increase in house prices experienced since 1996.

It is relevant to note in that regard that a seminal 2019 Bank of England working paper concluded that the rise in house prices relative to incomes between 1985 and 2018 can be more than accounted for by the substantial decline in the real risk‑free interest rate observable over that same period and that changes in that rate “were a crucial driver in house price changes”.

Ian Mulheirn’s study went on to posit that the housebuilding target of 300,000 would only result in a 10% decrease in the affordability ratio over 20 years. It would neither solve problems of high house prices nor low home ownership, but instead likely to result in further growth in the number of unoccupied (and under occupied?) homes, “which may not be an efficient use of scarce investment capital”.

Alternative policy solutions that it suggested included building more social housing or more generous housing benefit, “as these policies would help affordability-constrained young people”.

The CMA Study concluded that even a highly competitive private housebuilding market (which it showed did not exist) will not, on its own initiative, produce sufficient housing to meet overall housing need in accord with its wider (external) benefits (boost to productivity, education, health, and other outcomes) to society.

And, while private housebuilder incentives to build are likely to follow changes in demand, how well the housebuilding sector is delivering for consumers and wider society “is likely to be better captured by how far it is delivering against housing need”.

The CMA accordingly decided to focus on assessing supply delivery against housing need in its supply analysis (para 2.6, further evidence document).

Turning to housing demand, this, according to the Study, is determined “by the number of people or organisations willing and financially able to buy a property, either as a home, second home or investment property”; an outcome patterned by disparate factors, including aspiring buyers’ ability to sell their existing home, their access to housing equity or a deposit, their access to credit and the price of that credit (effective demand is interest-rate sensitive where prospective purchasers rely upon mortgage finance to proceed), their current income and future expectations, as well as the financial and tax implications of property ownership, their expectations of future returns, and wider market sentiment.

People will also often choose to purchase more housing when their incomes allow, for example, taking on properties with spare rooms or buying holiday homes. Thus, as real incomes increase, it can be expected – other things being equal, which, of course, they will rarely be, as above – that housing demand will expand proportionately more.

Because all these factors are constantly changing and are strongly linked to general macroeconomic performance, housing demand will fluctuate, making it difficult to measure.

In addition, buying, selling, and even moving house are all time-consuming and difficult endeavours involving high time and other transaction costs, including residential stamp duty, estate agents’ fees, removal, and reconnection costs, etc.

Consequently, people may not adjust their individual demand for housing immediately as their circumstances change.

The Study went on to posit that “although affordability is determined by factors such as household size and composition, credit conditions (including interest rate changes, presumably), population growth, and levels of household income”, if the supply of housing fails to keep pace with changes in demand, house prices can be expected to rise faster than earnings, so worsening affordability.

This the Study defined as “the level of housing outgoings (for rent, mortgage, etc.) which a household can (and will) meet from its recurrent income without significant risk of material hardship or financial stress, including the risk of being pushed into poverty”.

It has certainly worsened over time. A key ONS dataset reports that the median house price to median gross annual residence-based earnings affordability ratio rose from 5.11 in England and 6.9 in London in 2002 to 9.06 and 13.62, respectively, in 2021, before subsequently slightly falling back as house prices dipped in response to increased mortgage rates.

The Study itself reported that by 2022, full-time employees in England could expect to spend around 8.4 years of income buying a home, compared to 6.4 in Wales, and 5.3 in Scotland, noting that as rough rule of thumb, it should lie in the four to five range (mortgage lenders, for example, seldom lend more than 4.5 times of purchaser annual income).

Considerable variation within countries and regions (as well as between – exemplified by the London figures reported above) also occurs. All regions (except the North east) have LPAs in 2021 with affordability ratios of over five (see figure 2.4, CMA Supporting evidence document for an annotated and illuminating infographic defining the most and least affordable LPAs within each country and region. You could purchase then homes in Merthyr Tydfil, Barnsley, Copeland, Bolsover, County Durham, Copeland, and Stoke-in Trent, LPAs reporting an affordability ratio of less than five).

The Study pointed out such entrenched variation is likely to be symptomatic of a market that in supply response is unable to adequately adjust to consumer preferences, expressed through price signals, concerning the supply of available homes and their desired locations.

With respect to rental levels, the Study reported that the rental affordability ratio for both England and Wales since 2014 taken across the board has remained below the affordability threshold of 30% of income, used by the ONS as a normative yardstick.

More instructively, however, when lower quartile income (the income that 25% of households are at or below) are compared with the lower quartile rent (the rent that 25% of rental properties are at or below),  the ONS found that at a country level, in England and Wales, high, average, and low rents were all above the ONS’s affordability threshold and thus unaffordable for lower income households; and that they were only affordable for average-income households in Wales. In England only average and low rents were affordable for average-income households.

Quality, innovation, and sustainability

The Study recorded a lack of competitive pressure to drive up new build quality, related to factors both intrinsic to the characteristics of housing as a good and to specific shortcomings in the consumer regulation and oversight of the housebuilding market.

Intrinsic factors include that new build quality is difficult or impossible to observe prior to purchase. It becomes noticeable to purchasers only when something subsequently goes wrong. In that sense, the speculative housing market suffers from a similar market information failure or imbalance as does the second-hand car market – something the Study did not highlight.

Connected to that, prospective buyers also prioritise factors other than quality (which, as above, in any case, is difficult to observe or assess) as they hurriedly compete to complete a purchase in accord with their budget constraint and preferences and not to miss out on their hopes.

During this process they can fear that they will otherwise ‘miss the boat’ and be priced out (especially during periods of robust house price growth),  making them even more amenable to the assumption that housebuilders build to a baseline level of quality  – a reasonable one given the nature, importance, and expense of the good, when considered alongside associated seller publicity, which is often unclear and sometimes misleading (another information imbalance or failure).

The Study was clear that such information imbalances have not been rectified by the current voluntary consumer protection arrangements. It singled the House Builders Federation (HBF) Star Rating Scheme for criticism as of limited informational value, one which was not designed in the first place to ensure effective and timely rectification of defects.

Evidence of consumers encountering increasing and mounting difficulty and housebuilder resistance found by the Study when multiple number of snags or faults remain to be rectified, with a small but significant minority experiencing the most serious defects suffering significant consumer detriment: a serious matter and market failure for the most important purchase that most people make in their lives in terms both of their financial commitment and their individual/family future and welfare.

Levels of innovation in the industry were also found by the Study to seriously undershoot what it considered a dynamic, well-functioning market should foster and generate, noting that despite the largest housebuilders investing in, acquiring, or developing their own more innovative production capacity its dissemination continues to be slow, while sustainability efforts are primarily driven by expectations of future regulation, rather than endogenous (self-driven) industry momentum.

Profitability

The Study found that the profitability of the 12 largest housebuilders, delivering around 40% of total housing completions in recent years, exceeded what it would expect a well-functioning competitive market to provide, at least during “periods outside the Global Financial Crisis (GFC) and its immediate aftermath”.

That conclusion was based on a methodology predicated on the assumption that in a competitive market, a ‘normal’ profit was “the minimum level required to keep the factors of production in their current use in the long run: i.e. when the rate of return on capital employed for a particular business activity would be equal to the opportunity cost of capital for that activity”.

The rate of return that housebuilders achieved on their employed capital accordingly was compared to the opportunity cost of that capital between 2003 to 2022 inclusive.

Housebuilder profits from 2013 to 2019 were found by the Study to be particularly high against that ‘normal profit’ yardstick, because of supportive economic circumstances for housebuilders – in particular, low interest rates and quantitative easing – as well as by measures taken by the government to help homebuyers fund deposits for the purchase of new homes through the Help to Buy (HtB) scheme.

The Study highlighted that one large housebuilder, following the changes to the planning regime in 2012 was able to build out the strategic land bank it held at the time, thereby realising the greater returns associated with buying land without planning permission, before it then benefited significantly from increased HtB-driven demand; c60% of the homes sold by that housebuilder in 2018 were supported by that scheme.

Specifically, it (Table A:1) computed that during the 2016-19 period inclusive the return on capital employed (ROCE) achieved annually by the 12 housebuilders was between 29% and 34%, whereas its mid estimate (Table B.4 of Appendix B) of their pre-tax nominal annual cost of capital was between 14.4% and 14.6%: the observed profit of the largest housebuilders was thus double their expected ‘normal’ profit.

The Study had earlier confirmed (para 4.105, planning working paper, see link above) that, typically, housebuilders expect to achieve margins in the range of 15% to 25% on residential development sites, equating to approximately £46,000 to £77,000 per plot at average house prices.

It still concluded, nevertheless, that specific intervention (s) is not required to tackle such excess levels of observed profitability directly, as such intervention, according to the Study “could create an additional downward pressure on the number of houses being built, exacerbating the supply problems that have characterised this market over a long period”, because:

  • the housing market is highly cyclical and is impacted by external factors, including the wider economic climate;
  • profitability during the 2010s is likely to have been boosted by supportive economic circumstances and temporary factors no longer in evidence, in particular a prolonged period of low interest rates and the Help to Buy schemes’ support for first-time buyers;
  • there was significant variation in the performance of individual large housebuilders in the Study sample.

 2             Causes and consequences of housing market failure

The Study found that deficient housing supply and its affordability was propelled by, in effect, two (and a half?) key drivers:

  1. The nature and operation of the planning system;
  2. The limited amount of housing built outside the speculative approach (such as affordable housing, self-build, and build-to-rent), with private speculative build-out rates providing an additional (related?) factor insofar that it is both cyclical and calibrated to avoid impacting on market prices.

 Operation of the planning system

Insofar that a prior condition for building houses is possessing permission to build them, the Study found that the nature and operation of the planning systems is a key driver of the under-delivery of new housing at levels required to meet government targets and measures of assessed need.

That the number of planning permissions granted over the last 10 years across GB, and particularly in England, have been “insufficient to support housebuilding at the level required to meet government targets and widely accepted measures of need” was highlighted, with the number of units granted planning permission in England in 2022-23 falling to 269,000 after several years when permissions had exceeded 300,000.

The Study pointed that due to some applications lapsing because of viability or other reasons and the time lag between when a scheme is approved and when it is built out, achievement of the 300,000 target requires the number of applications approved each to exceed 300,000 to allow enough permissions to be banked over time consistent with the delivery target.

More broadly, the ability of the planning system(s) “to support the level of housebuilding that policymakers believe is needed”, is limited by its:

  • lack of predictability;
  • length, cost, and complexity; and the
  • insufficient clarity, consistency and strength of LPA targets, objectives, and incentives to meet housing need.

These problems, the Study added, may have a disproportionate impact on Small and Medium Enterprise (SME) housebuilders.

Four potential sources of unpredictability in the planning system were then pinpointed.

First, governments frequently use the planning system to implement new policies, most commonly environmental regulations resulting, in effect, administrative and policy overload on LPAs with limited resources causing consequent delay and confusion. Examples provided by the Study included nutrient neutrality requirements and biodiversity net gain rules in England.

Second, since the introduction of the National Planning Policy Framework (NPPF) in 2012, significant revisions have become more frequent in recent years, with the review process that starting with the 2020 Planning White Paper generating particular policy uncertainty at LPA and other stakeholder levels.

The most recent and, perhaps, notorious example was the December 2022 consultation on revisions to the NPPF, which, as this website in  and others warned would happen, has led some LPAs to delay or to even withdraw their Plans, and/or rescind previous application approvals.

The Levelling Up Secretary of State Michael Gove in a December 2023 Ministerial Written Statement announced the result of the government’s response to that consultation, in parallel publishing an updated National Planning Policy Framework reflecting the changes made.

In summary, the new 2023 NPPF, according to the government, is designed to: facilitate flexibility for local authorities in relation to local housing need, with the Standard Method (see below) for calculating housing need becoming an “advisory starting point” rather than a mandatory input for LPAs in their determination housing numbers; clarify a local lock on any changes to Green Belt boundaries; safeguard local plans from densities that would be wholly out of character; free local authorities with up-to-date local plans from annual updates to their five-year housing land supply and remove buffer requirements, save that a 20% buffer  will still be applied if Housing Delivery Test targets are not met; limit the practice of housing need being exported to neighbouring authorities without mutual agreement; bolster protections from speculative development for neighbourhoods that develop their own plans; support self-build, custom-build and community-led housing; and cement the role of beauty and placemaking in the planning system.

The 2023 NPPF also retained the 35% uplift to the assessed housing need for the 20 largest towns and cities in England and the requirement that it should be accommodated within those cities themselves, except where cross boundary redistribution agreements are in place.

According to the Study, the uncertainty arising from this latest review process have yet to be resolved, with many changes proposed to be rolled out gradually on a ‘test and learn’ basis.

Although it did not highlight introduction of the Infrastructure Levy (IL) by LURA that measure provides a prime case in point of planning reform generating confusion and uncertainty with its associated ‘test and learn’ issues risking potential and substantive future policy planning blight, as this website in Going around the Mulberry Bush  discussed in detail.

In February 2024, the UK government announced further changes focused on encouraging brownfield development, including a new consultation on changes to the NPPF involving introduction of a presumption in favour of brownfield residential development where a LPAs HDT result is both below 95% and it is one of the 20 LPAs in receipt of the 35% urban uplift, and a change that would expect all LPAs to give significant weight to the benefits of delivering as many homes as possible, and to be flexible in applying policies or guidance on the internal layout of developments, especially again in relation to brownfield land proposals.

There have also been significant recent changes in Scotland and Wales over the past few years.

Third, there is a lack of up-to-date Local Plans (LPs), especially in England, where on 31 December 2021, less than 40% of LPAs had updated their plans in the last five years. 22% had not either adopted a plan for more than 10 years or had no plan in place.

Updating a plan is a complex and lengthy process, with DLUHC estimates suggesting that the average time taken to produce a local plan is seven years involving substantial time and other resource costs.

The Study was told by some LPAs told us that they had difficulty getting plans adopted for political reasons, especially where the plan might require the release of green belt land to meet housing need, with analysis presented showing that the LPAs with either a significantly outdated plan, or no plan at all, typically have much higher percentages of greenbelt land within their boundaries (see Table 6.8, further evidence document).

The Study advised that LPAs with out of date or no plans  tend to the same ones that undershoot their Housing Delivery Test (HDT), (Table 6.5, further evidence document). The presumption of sustainable development ceases to apply to speculative applications where an LPA is not delivering more than 75% of its assessed housing need target, as it does where the LPA’s LP is out of date and/or where it cannot demonstrate a five-year housing land supply (5YHLS), subject to the changes made in the 2023 NPPF.

As way of background, the 2018 updated NPPF introduced both the centralised Standard Method (SM) to assess housing need and the HDT.  The SM is a baseline formula used to identify the minimum number of homes expected to be planned for in a way which addresses projected household growth, affordability and, in some cases, any urban uplift required by the 2023 NPPF.

It identifies a minimum annual housing need figure to be used in the HDT, not a housing requirement figure, which the individual LPAs are expected to define themselves.

HDT targets cover a three-year period with specific values set and calculated for each year, based on the lower of either the need level set out in an up-to-date Local Plan (LP) or the SM assessed need level. Where the LP is not up to date, as is the case for the majority of English LPAs, the HDT should assess local delivery against the local SM assessed need figure.

In short, significant underperformance of housing delivery against targets is limited to a relatively small number of LPAs, relatively highly concentrated in certain areas of the country, particularly in the South East, the East of England, and the London regions.

The Study cited its own analysis that 51 out of more than 306 LPAs (17%) in England achieved less than 75% of their need based HDT targets in 2021, whereas 214 (or 70%) of LPAs achieved more than 95% of their housing need.

The majority of the areas that achieved less than 75% (37) are located in the South East, East of England and London, with LPA performance in the HDT remaining broadly consistent since 2018 (see Table 6.1, further evidence document). The above, of course, are the same areas where supply deficiency and affordability problems and the population are most concentrated (see section 1).

The Study further found that LPAs with the highest delivery against their housing targets tend to process a higher number of applications relative to their housing stock; approve a higher proportion of those applications; have a lower proportion of their rejection decisions appealed; and lose a lower proportion of appeals, with converse being the case for LPAs with the lowest delivery against their housing targets.

Fourth, political and public attitudes to development are frequently expressed through the planning process. Residential development has become increasingly politically contested, delaying, and making harder timely Local Plan making and planning application determination, to the point that development applications and investment are discouraged.

The Study did, nevertheless, find that the strongest existing sanctions for LPAs to prioritise housing delivery exist in England, where a presumption in favour of sustainable development (due to the NPPF) comes into play if targets are not met. Housebuilders therefore have greater rights to have applications approved, compared to Scotland or Wales, where no equivalent incentive is in place.

Protected land or geographic constraints can undercut that presumption, however. Across many areas of England (footnote seven of para 66, NPPF), designated local green spaces, areas of outstanding natural beauty, national parks, heritage coast, irreplaceable habitats, heritage assets (and other heritage assets of archaeological interest), and areas at risk of flooding or coastal change, as well as designated green belt land are specifically excluded from the presumption.   The North West of England (53.1%) and the South East of England (49.6%) have the highest proportion of protected land in England

 The Study went on recognise that when all is said and done the planning system(s) was and is in large part designed to ensure that local preferences are incorporated into decision-making – adding the cavil that this does not necessarily lead to consistent decision-making at a local level.

Given that and “the wider policy trade-offs and complexities that are inherent in planning system design and operation”, the Study decided that it would be inappropriate for the CMA to make specific recommendations to governments about how such trade-offs should be made.

Rather, given “the vital role that (planning systems) play in shaping market outcomes” it offered options to make them more predictable and less costly, lengthy and complex for housebuilders.

But it left it up to governments to “consider whether the (associated) trade-offs with wider policy objectives are worth making, in the context of their overall objectives for the housing market”.

These are set out in Options 2.1 to 2.7, Appendix B.

To give a flavour of these planning options, Option 2.1 defines the features that would mark an effective methodology more likely to result in a local target that accurately reflects need:

  • ease of understanding – ensuring that the assessment of housing need is easily implementable and has results that are readily understood, will allow for national and local targets to be more readily accepted and outputs to be more easily disseminated;
  • using reliable evidence – using up-to-date and robust evidence will ensure that the target will more closely reflect current housing need. In addition, using evidence from credible and, where possible, publicly available sources will help ensure that the results are more easily understood and accepted;
  • regular assessment – regular calculation of the housing target will help to ensure that the target is as accurate as possible; noting, however, that LPAs need a degree of stability in the national target so that they can effectively plan to deliver their local housing target for the medium and long term. Updating the target too frequently could lead to increased uncertainty at a local level, as well as the national and local target losing credibility. To achieve the right balance, the target could, for example, be updated whenever updated national household projections are available, but no more frequently than this;
  • unadjusted outputs – noting that housing policy is a matter for governments and incorporating aspects of policy targets, such as brownfield land use, may be an appropriate way of achieving policy aims. However, reducing the incorporation of other policy aims in the methodology through adjustments will result in the target becoming less reflective of underlying housing need. Therefore, such adjustments should be kept to a minimum with limited scope for discretion for the governments in making such adjustments.
  • local alignment with national target – limiting local deviation from the agreed methodology will result in local targets that are more closely aligned with the national target.

Appendix B should be consulted for detail on the other options that the Study presented.

Wider operation of the speculative housing system and associated build out policy issues

The Study largely echoed the Letwin Draft Report analysis in concluding competitive pressure to supply homes at a rate that exceeds the current local absorption rate was weak, “limiting the number of homes that are built over a period, removing potential downward pressure on local prices”.

Letwin’s investigation into 15 very large sites in areas of high housing demand found that their median build out period from the moment when the house builder has an implementable consent is 15.5 years; or put another way, the median percentage of a site built out each year on average through the build out period is 6.5%.

It pointed out that across the large sites of over 1,500 dwellings that it examined the revealed market absorption or build out rate went on to limit the corresponding scope to provide cross-subsidies between the units sold at market values and the affordable dwellings, consequently retarding the rate at which housebuilders can and will build out the affordable housing that may be required by any applicable affordable housing Section106 (S106) agreement.

The CMA Study put forward Options 2.8 to 2.10, Appendix B to support a higher build out rate.

Under Option 2.8, LPAs could require increased diversity of tenure for larger sites to be granted planning permission, including raising the proportion of affordable, build to rent or custom build homes on sites.

Increasing the wider diversity of housing tenures (sub-tenures?) aimed at different sub-segments of the market, could consequently allow for more homes to be absorbed within the local market “without housebuilders needing to reduce the prices of the housing they produce for the private market, thereby improving the speed of housing delivery”.

LPAs could also publish their policy on housing tenure requirements, meaning that they are known by housebuilders and reflected in land transactions.

Such a requirement could be decided and operated in a similar way to LPA policies on affordable housing and developer contributions. The Study noted that the Letwin Final Report recommended a similar measure for developments providing over 1,500 dwellings, not then taken forward by the UK government.

With Option 2.10, LPAs could require housebuilders to increase the diversity of the types of homes (type, size, style, design, rather than tenure?) that they build on larger sites.

Sites with greater diversity of types may build out more quickly “as the varying types of homes entering the market are more likely to appeal to different sub-segments of the market and therefore such sites are less constrained by the local absorption rate”.

It went on to caution that were to support a higher build out rate the UK, Scottish, and Welsh governments to pursue these options that they should pay regard to the following considerations:

  • requirements for housebuilders to deviate from the profit-maximising level of site diversity could impact on viability and the number of sites developed;
  • to build a greater amount of affordable housing would likely require additional public funding, as such housing is sold to registered providers who are, at least in part, funded by government grants;
  • as with obtaining developer contributions, site diversity requirements must be consistent and not complex, as this would increase uncertainty and create delays in the planning process.

The Study concluded, however,  that whilst housebuilders could increase the rate at which they sell speculative homes by offering them for sale at lower price, as the number of homes that housebuilders can build (and therefore sell) in an area in the short to medium term is inherently limited by the planning system, “lowering their prices is more likely to bring sales of these homes forward in time, rather than increasing their overall sales over the medium term”.

Once a housebuilder has built out and sold the homes it has planning permission for in an area, it cannot simply sell more homes. To increase sales further a housebuilder must first obtain additional planning permissions, which, as the Study reiterated, is a lengthy and risky process, meaning that over the longer-term, “supply will depend on the extent to which they can get hold of further land with planning permission in the area”.

Yet, its overall conclusion was even if policymakers made the changes the Study proposed (as set out in Appendices A and B) “the market may still fall short of delivering the quantity of homes, supporting a level of affordability”, that policymakers find acceptable” because:

  • market outcomes are heavily influenced by external factors, such as interest rates, mortgage availability, the rate of new household formation, by demographic change and by the level of household incomes; and
  • market cyclicality and the speculative housebuilding model means that private housebuilders do not collectively have the necessary incentives to build houses at the rate required to meet policymakers’ objectives.

The Study went to say while it is open to policymakers to deliver change through more fundamental interventions “that go beyond the way in which the market itself works but would have a significant impact on the quality and affordability of new homes being built”, such interventions often come attached with “fiscal and policy implications”.

It accordingly declined to offer recommendations or specific policy options, but did identify areas of potential intervention because, “without them our analysis of this market and the potential outputs it can deliver would remain incomplete”.

These covered the encouragement of non-speculative housebuilding models, including self- or custom-build homes.  CMA, therefore, looked to the UK, Scottish, and Welsh governments to significantly increase their delivery of publicly funded housing by local authorities or housing associations to “supplement the absolute number of houses provided by private sector housebuilders, whilst incentivising housebuilders of these types of homes to deliver homes at a faster rate than under the speculative model”.

Governments “could consider” also a more active role for the public sector in the purchase and assembly of land for development. This the Study suggested could be achieved by granting LPAs additional powers to purchase land and/or to generate revenue to support development or through Community Land Auctions.

It further noted that the Letwin review recommended the establishment of more local development corporations with strong compulsory purchase powers and the ability to raise finance to fund local infrastructure.

In that light, the Levelling Up and Regeneration Act (LURA) since its enactment in October 2023 provides for LPAs to apply for a direction from the Secretary of State to permit Compulsory Purchase Orders to be used for specific projects in the ‘public interest’, such as education, healthcare, or affordable housing, without compensating the landowner for the potential uplift in the value of the land associated with the land being granted planning permission (hope value).

Alternatively, the Study went on, across GB, expectations of higher build-out rates could be reflected in national planning policy and in local plans. LPAs could set the build-out rate it expects housebuilders to achieve and be provided with greater enforcement powers where housebuilders undershoot the required build-out rate.

In addition, the UK, Scottish, and Welsh governments may “wish to consider” measures to increase housing demand, but should then have regard to the following principles:

  • stimulating demand without addressing the shortage in supply may cause house prices to rise. Therefore, implementing measures that increase supply would also be needed need to mitigate the risk that the gains from demand-side interventions accrue primarily to housebuilders and other sellers rather than buyers;
  • measures that seek to stimulate demand among certain groups of customers reduce the incentives on housebuilders to reduce their prices to attract those customers, or to attract other customers. Any intervention should therefore be carefully designed to “target those potential purchasers who would not otherwise be able to purchase a home”;
  • schemes that reduce the deposit requirement buyers face will also reduce the equity those buyers have in their home at the time of purchase, leaving “such buyers vulnerable to future mortgage and house price movements, with negative equity more likely”.
  • any demand-focused scheme will inevitably be temporary, risking unintended consequences, “including creating winners and losers among different groups of house purchasers over time: an important temporal aspect to consider when designing such a scheme”.

 3     Review and assessment

 The Study provides a comprehensive, evidenced, and useful policy commentary (well worth careful reading for its informational and review value), rather than – as might be expected given the CMA’s formal remit to promote competition and to protect consumers – a focused technical dissection of the housebuilding market from an economic, consumer welfare and competition perspective.

Consequently, sometimes it reads more as a policy critique and reform commentary than a market analysis, written by a specialist campaigning organisation or a think tank, reprising key elements of the government’s 2019 Housing and 2020 Planning White papers, and other recent government reviews, notably the Letwin Review.

Accordingly, the Study has already been criticised by some as straying outside its territory by “not minding its own business”, indulging in wishful aspirational group-thinking distracted by well-meaning and often frequently put well-rehearsed generalisations covering the firs area of concern it identified – producing more homes overall, particularly in the areas of highest demand – that risk gathering dust within the corridors of Whitehall rather than acting quickly and directly on the policy dial.

Indeed, a danger is discernible that policy focus is thereby diverted away from its key recommendations it made to government concerning improving consumer protection and information arrangements and the private management of estates (covering the second and third of the areas where the Study identified that government intervention was required to deliver better outcomes), potentially distracting attention away from evidenced reforms and action that the CMA could and should effectively progress itself with central government, squarely within its statutory remit.

Although invariably the Study’s analysis and conclusions made from an objective technocratic standpoint are perfectly sensible and correct, it (perhaps necessarily, and certainly understandably) neglected the political force and dimension of the reasons (largely political economy based) giving rise to the problems that it identified and their constraining effect on effective remedial public action.

For example: national housing targets should be set “in an objective way that better reflects need in a more certain and consistent manner to avoid the counterproductive confusion and uncertainty of recent years, underpinned by a methodology that is easy to understand that uses reliable and up-to-date information, and is assessed at regular intervals to ensure it remains reflective of need with the government provided limited discretion to adjust the original calculation”.

As the last section recorded, the Study went on to suggest using demographic projections as a default regular mechanism to update need assessments. These, however, can fluctuate depending on the assumptions applied, resulting in large swings in local figures that require dampening or, in other words, the exercise of central government ‘discretion’; moreover, it is far from clear that such ‘a predict and provide’ indicator subject to uncertainty is the best one to use.

It probably would have been more helpful to systematically tabulate the different possible ways that local housing targets could be constructed, their pros and cons and other salient considerations, rather than just plump for one option in an ill-considered way.

The overall objective to make local target setting more consistent and certain makes perfect sense but is one hostage to politically disruptive events, inevitable in a competitive political democracy subject to the political economy characteristics of the UK, and of England especially.

One such disruptive event was the 2021 Chesham by-election when the Conservatives lost to the Liberal Democrats in a campaign coloured by concerns of additional housing adversely impacting on the local environment and the quality of life of a generally well-heeled population. It practically acted as a death sentence on the 2020 Planning White Paper.

Likewise, the December 2022 NPPF consultation and the subsequent December 2023 changes cannot be divorced from government political electoral concerns that similar affluent seats across the ‘Blue wall’ of the London environs – including the Surrey Heath seat of Micheal Gove, the current Secretary of state – could be lost at least in part due to similar concern.

Key political economy characteristics other than Nimbyism and the associated tension between local democratic preference and the levels of central compulsion needed to secure nationally set objectives, include the real fiscal crisis of the state, lack of institutional capacity at both central and local levels, as well as the time divergence between the short-term concentrated cost and political pain of planning and other housing reform measures versus their long-term diffused benefits. A tension that can undermine and discourage the levels of sustained political focus needed for desired change to be effectively and substantively actuated.

A more fundamental criticism of the Study was its choice to focus on the extent that housing need is being met as the key metric of effective supply delivery. This comes across as mixed up, big time given that its purported focus was the housebuilding market.

In short, there is no reason why speculative housing market should deliver supply sufficient to meet normatively defined levels of housing need rather than effective demand. Many in housing need will be unable to afford or access the speculative market; and put simply, private housebuilders cannot be expected to act as housing charities.

That is not to say that it would be more economically and socially optimal for private housebuilders to migrate down the value chain and make a more diverse tenure and type offer, consistent with Options 2.8 and 2.10 that the Study advanced (see previous section).

It should have logically gone further and concluded that unless the share of such housing approached 50%, neither the 300,000 nor an alternative target based on housing need will be met.  But, as noted earlier, the Study concluded instead that while this might bring forward additional housing supply, overall, it would not increase numbers in total as these are constrained by the planning system and its ability and capacity to generate sufficient additional planning permissions. That, however, does not necessarily follow.

Indeed, at a practical policy level, the achievement of a sustainable stable and less volatile annual new supply level of 300,000 dwellings in England presupposes a much-enlarged state-enabled housing sector providing or enabling at least 100,000 dwellings a year, whether of social rented or intermediate sub-tenure: 50,000 more or broadly double than the average level of affordable gross supply achieved over the last decade, (see, Annex Table Four ) 

The Study itself reported that, since the Second World War, private developer output has fluctuated between roughly 150,000 and 200,000 dwellings per annum, implying that between 100,000 and 150,000 of a 300,000 total target will need to be met from other sources.

Not only would increasing the share of affordable housing (or requiring it to be built earlier) increase the supply of affordable housing sooner but such an intervention could encourage LPAs to approve applications in the first place.

Also, if the 300,000 target is to be attained, schemes of 2,000 homes of which 1,000 are affordable need to be approved rather than 1,500 homes of which 500 are affordable.

A connected conceptual problem with the Study was that its twofold diagnosis of deficient housing supply and affordability – the nature and operation of the planning system and the limited amount of housing being built outside the speculative approach (such as affordable housing, self-build, and build-to-rent), alongside with too low private speculative build-out rates– was sometimes likewise confused.

Subsequent media attention has largely focused on the emphasis the Study gave to the negative impact of the planning system on market outcomes and the resulting need for the system(s) to be made more predictable and less difficult and costly to navigate, and on occasions the Study seemed to assume that  the planning system provided the overarching problem and that its reform would provide the needed remedy to systemic housing under supply.

Yet it also emphasised that the private speculative housing market due to its particular and developed characteristics and its sensitivity to wider macro-economic conditions meant that model was intrinsically incapable of meeting societal objectives.

In the view of this website, it would have been more intellectually honest and potentially more impact effective (as well as more in accord with its remit) for the Study to highlight that an incremental and partial shift to a contracting rather than speculative provision model was a necessity  if policymakers declared objectives are to be attained, referencing that conclusion to robust and evidenced demonstration of housing market multiple failure.

Such a shift should increase the market absorption rate as well as both total and affordable housing supply. Known public purchases of affordable housing should involve a far lower profit rate than is currently levied and expected on speculative housing as housebuilders would no longer be subject to demand risk, although they would still be subject to some economic risk concerning construction and other costs.

But the levels of expanded public supply consistent with the attainment of the 300,000 target will require additional public funding, bringing it into conflict with the real fiscal crisis of the state: the unwillingness of governments to raise or commit to levels of needed social expenditure due to unwillingness to tax or borrow the necessary sums.

That crisis is not simply a reflection of real economic or financial constraints but also one of underlying denial that UK governments can both achieve desired social objectives based on citizen expectations of service delivery and quality as well as pursue the goal of low taxation.

But the Study, when recognising that the supply share taken by government-supported affordable housing must increase if supply targets are to be met, qualified that conclusion by recognising the policy and resource trade-offs involved, including increased public grant support versus wider macro-economic and public finance imperatives and increased developer contributions versus scheme viability considerations. In other words, it soon reverted to bureaucratic caution, pulling its punches.

So, on one hand, the Study went on ‘right-on’, boldly arguing on the primacy of housing need – as one would expect Shelter and Crisis to do – while, on the other, it then shied away from following the hard policy implications of that chosen approach.

The need for increased affordable housing and social rent has been previously advanced not infrequently by parliamentary Select Committee findings (often populated by MPs in favour of lower taxes and fiscal prudence), that then attract an invariably anodyne governmental response.

Certainly, the issue that must be understood and tackled is, why successive governments of whatever political colour, despite widespread cross party and public support for more affordable housing, have failed or felt unable or unwilling to act in the manner recommended by endless parliamentary committees, successive commissions of the ‘great and good’, as well as much of the mainstream media.

It would have more useful and pertinent for the Study to have queried the seriousness of intent of the UK government’s supply target; in short, is it simply aspirational or, put more cynically, an example of “wishful verbiage” (as a recent commentator put it in a wider political context) rather than a public policy objective backed by real political, financial, and institutional commitment.

If the former, the Study will be one of many that in the past and no doubt in the future that has or will say much the same things, without any or little policy impact, as this website’s earlier submission to the Study, tracked.

Of course, the CMA cannot directly intrude into the sphere of macro-economic and public finance management, but simply recognising such fundamental trade-offs hardly takes matters further.

Rather it behaved more like a pressure group facing both ways. By taking assessed housing need as the correct determinant of target setting – even though, as described earlier, that most studies indicate that would require substantial upward revision of national and local targets (above the national 300,000 level).

Such upward revision, however, would involve further methodological and process change – the same that the Study cautions against on planning certainty grounds and, in any case, would prove an exercise in futility insofar there is no prospect of a higher target being anything other than aspirational in the current and foreseeable policy environment.

The Study also at the same time seemingly ‘swallowed’ developer takes on profitability, viability, and the relationship of the second hand to the new home market.

While the much larger second-hand market (c90% of purchases) may put a partial lid on new build prices in particular locations and contexts, the new build and the second-hand market are not one and the same (perfect substitutes).

Many the housebuilders migrate up the value and price chain and as the Study itself highlighted the new build market has been underpinned by government interventions, most notably in the past by the HtB; nor should the impact of the information imbalances between housebuilder and new build purchasers be under-estimated.

Indeed, the Study itself noted the existence of a new home premium (perhaps 5% in some locations). Its figure 9.1 (supporting evidence document) suggests that during the upward part of the house cycle that premium increases.

The circularity of the argument that reducing housebuilder profits will or may reduce development viability should also be understood.  This is true only to the extent that c20% profit levels are treated as a fixed parameter – predicated on an assumption that they are a necessity – reflecting the characteristics and failures of the market as currently configured.

A six or seven per cent profit level rather than one in the 15% to 25% range represents a difference in price of between £30,000 and £50,000 per home for a home valued at c£300,000, making a big difference at the margin on affordability levels.

Many housebuilders have emphasised that policy certainty and clarity was more important than, for instance, the existence or the level of housing contributions, which they could then factor into their business plans and plan and respond accordingly.

The Study itself also identified evidence that developer contributions could be increased especially on greenfield sites, suggesting that a more consistent and certain approach could induce such an increase.

The fly in the ointment that remains is the associated need to underpin such a partial shift to a contracting model with increased public grant and policy support within the real fiscal crisis of the state, perhaps explaining why the CMA felt that a focus on the planning system was more expedient and more immediately policy relevant, notwithstanding the case made above that is was not intellectually robust  and consistent – cognisant of the prospect that planning reform has been declared as representing an early priority of a new Starmer-led government. That choice is revealing, perhaps, of prevailing civil service attitudes during what is likely to be a political transition year.

4             What should the next government do?

The political and policy challenge is to select and progress the line of least resistance to effectively reform Britain’s flawed institutional housing model, done in such a way that puts both total and affordable supply onto an upward trajectory to a sustainably higher and less volatile level more aligned to national economic and social needs.

The working assumption made here is that a new Starmer-led government, elected sometime in the autumn/winter of 2024-25, facing an immediate economic and political imperative to boost growth sooner rather than later to safeguard and release resources for necessary and vital public service provision and reform without increasing headline direct tax rates, will prioritise planning reform.

This in line with Starmer’s stated commitment that the government will “build rather than block” to support the provision of 1.5 million homes – equivalent to 300,000 homes per year – during the lifetime of the next parliament.

Indeed, it appears that Labour hopes that planning reform by generating a recovery and increase in housebuilding will kickstart the new government’s attempts to achieve higher growth, sidestepping the constraints on additional public investment that the debt reduction component of the fiscal rule framework (public debt as proportion of gdp will fall within five years) will impose.

Rachel Reeves, in her March 2024 Mais Lecture, confirmed the set fiscal rules as central to achieving macro-economic security and stability – the essential states of sustainable steady production-rather than debt-fuelled growth, in her economic worldview.

An alternative view and context is set out in his MainlyMacro blog (Tuesday 26th March)  by an economist who has been instrumental to fiscal rule development, pointing out further that capacity material and labour constraints – likely to especially acute within the housebuilding industry (something that the CMA study omitted) –  actually requires private consumption to be dampened by across the board tax increases.

The inevitable and potentially prolonged time lag (before any planning reform translates into building activity, and certainly into completed homes) translates into growth and productivity outcomes, presents an immediate problem.

That underscores the need for the new government to act quickly, decisively and with laser-like focus, notwithstanding the incessant competing pressures and priorities that it will inevitably face.

If it doesn’t, any prospect of Labour achieving its housing target will be hobbled at the start. On the 300,000 target itself, it is fair to say that it is a figure that has little or no evidential basis, whose virtue seems to be that it is a convenient round number, higher than current supply performance, which has been achieved in the past.

The location, type, and affordability of dwellings provided (composition) are as least, if not more important, than the bald total. The reason, of course that governments, or oppositions expecting to be the next government, do not disaggregate the supply target down into an affordable component is because their insufficient public housing investment would be exposed.

That said, the set target is understandable and visible and, if assumptions are strained to breaking point, potentially achievable – at least temporarily or fleetingly during the peak of the housing cycle.

Yet its current definition is unrealistic. Insofar that it unlikely that net new supply during 2024-25 and then 2025-26, will exceed 250,000 dwellings, a shortfall against that target will start to clock up from the outset. That new supply completions by 2029-30 will be closer to 400,000 than 300,000 (reflecting start levels of that magnitude during 2026-28), sufficient to offset early under performance, is simply not credible.

The lack of effective critical scrutiny is depressing. Even more so, it suggests, that Labour’s commitment to build 1.5m homes is for political show rather than made in serious intent.

Certainly, whether that is an unfair and unfounded accusation will become apparent soon enough. Unless its target is supported both by a committed strategy, detailed policies, and annual plans (very much a ‘Mission’ approach, echoing the committed efforts of early post war governments to achieve 300,000 new homes annually), it can be safely assumed that Labour’s target, as was the Conservatives, will remain an aspirational sop to ‘polite society’ rather than a ‘blood and guts’ political programme.

That Mission should be all encompassing, covering not only New Town and Urban Extension policy and planning, LPA empowerment, the declassification of ‘grey’ green belt land, and affordable housing, but also flats above shops/pubs, transport node densification, and community housing.

The shadow housing spokesperson has promised the imposition of “mandatory targets that bite on individual local planning authorities”.  Settling on what objective sustainable basis they are to be set at a local level itself will take time, given consultation requirements, as would other associated changes consistent with it, such as the conditions when Green Belt land can be used for housing, some of which, such as co-operation with other LPAs, may require primary legislative amendment to LURA rather than NPPF revision (the author of this post is not a planning expert and expects the Shadow Levelling Up and Housing teams to be fully engaged now in working through these issues ready for alternative government detailed engagement with the civil service) .

Rather than getting hang up on what demographic projections should be used, simpler metrics such as local affordability and past delivery (perhaps measured by delivery of additional housing per 1000 dwellings could be used, if possible.

But Gove’s December 2022 changes (Gove changes) should be rescinded with best possible alacrity and replaced with emergency guidance that LPAs in future will be expected to deliver locally housing volumes that summed across the country are consistent with the achievement of the national 300,000 target with some additional buffer provided, covering the points below and others.

LPA’s that have paused Plans or rescinded planning approvals in the wake of Gove changes, should be individually instructed to resume Plan-making in line with that target, as should LPAs without an up-to-date Plan, and given a deadline to do so, monitored by the DLUHC, or whatever its successor may be called. Rescinded approvals should be revisited in line with the new guidance again within a deadline, which if missed will mean that determination by the Independent Planning Inspectorate.

Securing change working with such ‘reluctant soldier’ LPAs will not be easy. However, it is best to take any political pain in the early period of government, necessary in any case because of the timelag issue, as identified above.  Any ‘Chesham’ effect will be better withstood earlier than later in the government’s lifetime.

The CMA Study, indeed, provides civil service and administrative cover and support for such actions and thus now provides a timely and useful resource.

LPAs should be given every possible encouragement and incentive to deliver additional housing sooner rather than later whether through mechanisms, such as the New Homes Bonus, infrastructural and other financial support, the expeditious approval and support of New Town Local, and other Development Corporations where appropriate, and though linkage to measures more specifically designed to increase affordable housing, such as lifting local borrowing caps and the use of CPOs,  as well as the reinstatement of 100% receipt recycling, especially across areas where additional housing is both most needed and most likely contribute to productivity enhancement.

Then, of course, the overarching real fiscal crisis of the state overarching constraint could bite. Yet, public infrastructural investment in transport and sometimes other supporting social infrastructure, will invariably be required to pump prime private housing development investment in relation to large scale schemes.

These include the Oxford-Cambridge corridor, New Towns and urban extensions, and transformative brownfield urban developments, such as along the Thames estuary.

The same point applies to the necessary shift away from the private speculative towards a more towards a more public contracting partnership model, where upwards to 50% of the annual 300,000 additional housing target is affordable, custom-or built to rent.

Without such a shift, the 300,000 target, cannot and will not be met. It will require, however, some additional public funding support and guarantees that, in turn, will need to be an integral part of the 2025 Comprehensive Spending Review process.

It must be understood that if funds are not apportioned to public infrastructure and housing investment, neither the new government’s overarching economic nor its housing objectives will be met. As such it will provide an early test of the pragmatism – both in wider economic as well as political terms) of the application of Labour’s fiscal rules, as well as of its housing policy.

In planning policy terms, early planning guidance could provide a nudge in that direction by indicating an expectation that 50% of additional new supply should be locally affordable, whether officially defined as such or targeted to home buyers at lower quartile prices. Early delivery of affordable housing within large schemes along the lines that Letwin advocated should be put in train.

Creating a fast-tracked route for in-principal approval for applications that are in line with an adopted local plan, providing housebuilders with greater certainty to begin development, could also enter the policy menu.

Appendix A

Preventing the proliferation of private management arrangements on new housing estates

Recommendation 1.1: Common adoptable standards

The UK, Scottish, and Welsh governments each implement common adoptable standards for public amenities on new housing estates.

Recommendation 1.2: Mandatory adoption

The UK, Scottish, and Welsh governments each implement mandatory adoption of public amenities on new housing estates (outside of minor, well-defined exceptions).

Providing greater protection to households living under private management arrangements Recommendation 1.3: Enhanced consumer protection measures

We recommend that the UK government, in consultation with the Scottish and Welsh Governments, introduce enhanced consumer protection measures, underpinned by a robust enforcement regime, for households living under private management arrangements. Recommendation 1.4: Prohibition of new embedded management arrangements

The UK, Scottish, and Welsh governments each prohibit the establishment of new embedded management arrangements.

Recommendation 1.5: Guidance for residents’ management companies

We recommend that the UK, Scottish, and Welsh governments each provide guidance to members and directors of residents’ management companies to support and enable them in effectively managing the amenities on their housing estates.

Quality of new homes produced and service provided by housebuilders A single mandatory consumer code and the New Homes Ombudsman Scheme

Recommendation 2.1: A single mandatory consumer code

The UK government, in consultation with the Scottish and Welsh Governments, develops and approves a single mandatory consumer code for all housebuilders operating in GB. Recommendation 2.2: New Homes Ombudsman Scheme

The UK government, in consultation with the Scottish and Welsh Governments, activates the New Homes Ombudsman Scheme.

Eliminating drip pricing and providing greater clarity to buyers regarding the true cost of their new home

Recommendation 2.3: Prohibition of drip pricing

The UK government, in consultation with the Scottish and Welsh Governments, establishes a specific banned practice on the drip pricing of all mandatory elements of a new home, as well as other charges that are presented as ‘optional’ but which it is reasonably foreseeable that most consumers would have to pay, even if others could avoid them.

Recommendation 2.4: Disclosure of optional extras

The UK government, in consultation with the Scottish and Welsh Governments, requires that where housebuilders present consumers with genuinely optional extras as a part of the purchasing process, these optional extras and their prices are prominently and fully disclosed alongside the headline price.

Developing an independent single consumer satisfaction survey and publishing key quality metrics

Recommendation 2.5: Single consumer satisfaction survey

The UK government, in consultation with the Scottish and Welsh Governments, requires an independent body to develop, maintain and undertake a single consumer satisfaction survey on the quality of new homes and the service provided by all housebuilders.

Recommendation 2.6: Publishing key quality metrics

The UK government, in consultation with the Scottish and Welsh Governments, requires housebuilders to participate in the survey, display their key quality metrics to consumers, and share this information with an independent body for public dissemination.

Appendix B

Reforming the planning process

Option 2.1: More objective and effective use of targets to ensure housing need is met.

Governments are best placed determine an appropriate methodology to set a national housing target. In determining an appropriate methodology, the governments will need to consider: (a) how LAs could effectively align their local plan with the national target; and (b) whether and, if so, how the target should reflect the need to address existing levels of supply, as well as meeting future housing need.

Option 2.2: Effective monitoring and enforcement of local plans to encourage housebuilders to bring forward successful planning applications and build new houses.

  • LPAs should be incentivised to have an up-to-date local plan in place. Incentives could include: ringfencing funds that LPAs can use only if they have an up-to-date local plan in place;
  • making it more difficult for LPAs to reject planning applications if they do not have a local plan in place or if they do not have an up-to-date plan in place;
  • central governments taking over the decision-making authority in a local area until a local plan is in place and as a last resort, imposing a local plan on the LPA, noting that “this would go further than the government’s recently announced plans to drive an improvement in local plan production”.

Option 2.3: Streamlining the planning system to significantly increase the ability of housebuilders to begin work on new projects sooner and bring forward marginal projects which may have previously been non-viable due to the costs of taking them forward.

The UK, Scottish, and Welsh governments could consider the following options for streamlining the planning systems:

  • increasing the emphasis on local plans as the key means by which communities and their elected local officials decide the amount, mix, design, location, and overall standards of new housing in their area, rather than by reviewing planning applications on a case-by-case basis;
  • creating a fast-tracked route for in-principle approval for applications that are in line with an adopted local plan, so housebuilders have greater certainty to begin development;
  • formally reviewing the varied LPA schemes of delegation with a view to harmonising the complex set of rules and removing the use of Planning Committees for those applications which are broadly in-line with the local plan and/or which below an agreed threshold;
  • improving the appeals process, as informal hearing and written representations appeals can cause delays and have an adverse impact on the delivery of smaller housing schemes and on SME housebuilders.

 Improving the planning processes

Option 2.4: Clearly defining and rationalising statutory consultees to reduce the delay caused by the statutory consultation process.

 Option 2.5: Effective monitoring and enforcement of deadlines for statutory consultees so as not to unnecessarily delay the planning process.

Measures to support reforms to the planning systems and processes

Option 2.6: Improving LPA capacity and resource by raising planning fees to a cost reflective level and ringfencing those fees.

Option 2.7: Additional support for SME housebuilders through better guidance, standardised LPA policy and a simpler ‘outline’ stage of planning permission.

Measures to support a higher build-out rate

Option 2.8: LPAs could require greater diversity of housing tenure for larger sites to be granted planning permission.

LPAs could require increased diversity of tenure for larger sites to be granted planning permission by increasing the proportion of affordable, build to rent or custom build homes on sites allow for more homes to be absorbed within different sub-segments of the local market(s) without housebuilders needing to reduce the prices of the housing they produce for the private market, thereby improving the speed of housing delivery.

They could publish their policy on housing tenure requirements, meaning they are known by housebuilders and reflected in land transactions to be decided and operated in a similar way to LPA polices on affordable housing and developer contributions, noting that the Letwin  Final Report recommended a similar measure for developments providing over 1,500 dwellings, although it has not been taken forward by the UK government.

Option 2.9: LPAs could be incentivised by governments to increase the number of homes that are delivered through smaller sites.

The UK government’s NPPF requirement that LPAs should identify land for at least 10% of their housing requirement on sites no larger than one hectare could be strengthened to require explicit identification of the sites that will comprise this 10%, alongside regular enforcement of the policy. A similar policy could also be considered by the Scottish and Welsh Governments, to support SME housebuilders and increase housing delivery rates.

Option 2.10: LPAs could require housebuilders to increase the diversity of the types of homes they build on larger sites.

LPAs could require housebuilders to increase the diversity of the types of homes (type, size and style, design, rather than tenure?) that they build on larger sites. Sites with greater diversity of types may build out more quickly as the varying types of homes entering the market are more likely to appeal to different sub-segments of the market and therefore such sites are less constrained by the local absorption rate.

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Filed Under: CMA Study, Housing, Macro-economic policy, Real Fiscal Crisis of the State, Starmer Tagged With: CMA Study, housing, real fiscal crisis of the state

Making Public Investment Smart

12th June 2019 by newtjoh

The level and quality of public infrastructural investment must meet macro-economic and social requirements and be efficient in selection and execution.

The establishment of the Infrastructure Projects Authority (IPA) in 2016, and the National Infrastructure Commission (NIC) in 2017, was a move in the right direction in line with that. It provides potentially a stronger institutional footing for the effective planning, funding, selection, and execution of infrastructural projects, which, hopefully, is associated with a better shared political understanding of the role that productive public infrastructural investment must play in underpinning a future sustainable productivity-driven growth economy.

Yet the fiscal and institutional environment for the funding, selecting, and delivering of infrastructure, remains, unfortunately, unfit for purpose.

The need to change that, and how, provided the tread for the Submission that A Social Democratic Future made this month in response to HM Treasury’s Infrastructure Finance Review, which closed on 5th June, (the Consultation).

The Consultation sought views on securing private finance in support of productive infrastructural provision in such a way that the ‘benefits brought by private finance must outweigh the additional cost to the taxpayer of using private capital’, (para. 1.9), and on the future institutional options for delivering government support for infrastructural finance, including establishing a new operationally independent institution in the expected post-Brexit environment, when the UK will no longer benefit from access to the European Investment Bank (EIB).

Continuing under-investment in both productive economic and social infrastructure will retard the achievement of the step-increase in growth and productivity required to escape continuing stagnation. That is the prime issue.

This means fostering and reaping the potential productivity gains that follow the agglomeration of specialized economic activities in the largest urban areas and other concentrated clusters, including improved matches of jobs and people, the sharing of information, knowledge and innovation, as well as facilitated market access.

Bigger and more people-dense high-productivity cities, in turn, will depend upon high quality transport, digital, and social infrastructure in housing, education, and, to a degree, cultural services.

In the UK context, that means supporting primarily the densification of London, and other high-productivity clusters that could potentially conflict with regional spatial and social equity and cohesion aims, and, certainly, is in tension with them.

The post-Brexit referendum environment has further highlighted that tension, and underscored both an economic and social imperative to support and foster the recovery and rejuvenation of ‘left-behind (or neglected) Britain’  for choice of a better descriptive phrase. Coastal and smaller cities and towns, especially in sub-regions located north of a line drawn between the Humber and Wash and in Cornwall spring to mind. They have borne the brunt of decades of de-industrialisation and/or relatively stagnant or declining service sectors – the same areas that tend to the most exposed to the future loss of EU Structural Funds.

Both these strategic policy drivers put an added premium on moving to a reformed and inter-linked fiscal and institutional environment that can best deliver efficient productive infrastructural investment.

Take a sustained increase in affordable housing investment to a known broad steady-state level, planned and meshed with the targeted and planned expansion of apprentice and training opportunities to indigenous workers: although it should help to secure structural change in the construction industry and a step-change in its productivity, it is presently prevented, however, by the operation of the current public expenditure system, where housing capital allocations are constrained by rigid fiscal limits.

The current unitary cash-based public expenditure system lumps together recurrent revenue and lumpy investment expenditures producing future financial, economic, and social benefits into the future.

The construction and provision costs of providing new dwellings is consequently front-loaded  as public expenditure contributing to the deficit into the short-term, leaving public investment, and the housing programme in particular, disproportionately prone to cuts during periods of fiscal stress or austerity (generally when increased counter-cyclical investment is required, as was the case in the wake of the-GFC, nut when it was by cut by 40% in the 2010 SR), and, more generally, constrained below optimal economic levels by undiscriminating unitary fiscal targets, such as when Parliament in January 2017 committed the government to reducing the cyclically adjusted deficit to below 2% of GDP by 2020-21 and having debt falling as a share of GDP in 2020-21.

In contrast, homebuyers budget to meet their recurrent mortgage costs, not the full value of their mortgage; nor are they double-counted.  Nearly all first-time buyers could not purchase if the same accounting treatment was applied to them.

The Fiscal Remit imposed on the NIC by HM Treasury – itself constrained by that same  discrimination against investment expenditure, intrinsic within the current cash-based unitary public expenditure system – sets a gross public investment funding envelope or limit of between 1.0% and 1.2% of GDP in each year between 2020 and 2050, within which NIC recommendations for economic infrastructure must adhere, after taking account of existing funding commitments, including HS2, CrossRail 2, and Northern Powerhouse Rail. This is even though that existing commitments – combined with expected maintenance spending on existing assets – will consume an estimated 1.1% of GDP between 2020 and 2025, and 0.9% between 2025 and 2030.

Very limited fiscal space, over the short-to-medium term, therefore, will be left for the NIC, by its own reckoning, to recommend new and additional projects, such as the upgradations and new additions to the intra-and inter-urban transport network needed for the posited benefits of HS2 for London and other urban conurbations to be substantively harnessed.

Likewise, projects that could step-up the productivity of under-performing urban agglomerations such as the West Midlands, currently held back by congested and inadequate public transport connectivity, closer to European average levels, will almost certainly be stuck on the drawing board or stillborn.

Its constrained Fiscal Remit will also undermine any effort of the NIC to select, rank, and sequence projects – given their lumpiness and interdependency – efficiently.

For example, it is unlikely that the London transport system could cope with increased HS2 numbers without the prior of completion CrossRail at the London Euston terminal end.

Most HS2 passengers arriving and departing at Birmingham will still also need to get to the terminus station by public transport, unless they can walk to a central destination or get a taxi to a poorly connected destination within the West Midlands conurbation.

Already, productive infrastructural projects have been pared back due to fiscal constraints linked to the achievement of short-term fiscal targets. Trans-Pennine Rail provides a recent example with likely significant sub-optimal economic effect on the Greater Manchester and West Yorkshire economies.

Another problem with the current fiscal rules is that debt raised by Public-Private Partnerships (PPP)’s to construct assets – within the current cash-based public expenditure planning system (if it meets defined accounting tests) – is not recorded as public spending or debt.

Unless public procurement and PPP’s are put firmly on a level playing field, the ‘fiscal illusion’, as the Office of Budget Responsibility (OBR) in 2017 described the Private Finance Initiative (PFI) programme, which Budget 2018, PF1/2 curtailed, risks repeat.

Private finance will then continue to be used to meet the infrastructural funding gap, even where it involves net higher public costs and hence public debt and borrowing over entire project lifetimes.

Alternatively, private financing of new water and energy assets under the current Regulated Asset Base will rely upon their ultimate funding on hidden subsidies and higher charges on consumers, with resulting regressive incidence on household budgets.

The effective development of the NIC’s proposed analytical framework for comparing the whole life costs and benefits of private financing and traditional procurement on an objective whole-life project basis, accordingly, and in addition, also depends upon inter-linked fiscal and institutional reform.

The Submission recommended integrated reform across three primary areas: the fiscal rule framework; the institutional environment governing the selection, ranking, and delivery of productive economic and social infrastructure projects; and tackling the root causes of the rising relative real cost of providing of such infrastructure.

Fiscal Rule Reform

The 2019 Spending Review (2019SR) should increase the NIC’s current Fiscal Remit funding envelope and disentangle it from unitary cash-based fiscal targets, while the NIC should provide evidenced assessment of the future volume need for public investment, and its sequencing, to the Treasury.

Capital spending on both conventional and PPP’s should be freed from year-to-year financial cash-limits, but their modelled future revenue liabilities included in future government debt projections used to assess future debt sustainability.

And the IPA and NIC should ensure that choice of procurement route for future publicly supported or regulated infrastructural provision should strictly and wholly be determined by relative whole-life project efficiency, taking account of the cost of finance, according to the best-available tools and evidence-base.

The selection, ranking, and delivery of productive economic and social infrastructure projects.

It is not apparent that the impact of future technological change on the economic value attached to shorter journey times between Birmingham and London, nor the actual scope potentially available in the future for existing networks, such as the Chiltern line, to increase capacity and average journey times, were adequately addressed during the original HS2 decision-making process.

At any rate, a fully transparent evidence-base does not seem to be available to convincingly rebut rising doubts, currently raised within and outside Westminster, concerning the vfm and the ultimate economic utility of the project – attached with an expected price-tag of over 55bn – relative to alternatives.

The Thames Tideway project – a 25km tunnel, currently in the process of construction, to upgrade and expand London’s Victorian sewer network will cost an estimated final c4.2bn at 2014 prices. A Special Purpose Vehicle (SPV) bears primary construction and execution risk. That feature and an innovative patchwork of public guarantees and retention of high impact but low likelihood risks, designed to avoid expensive and inefficient risk pricing, has led many to tout it as an emerging PPP model, but the business case need for the project relative to cheaper alternatives, such as improved maintenance and repair of the existing network to prevent leakages, has been questioned.

Ultimate project risk will rest upon the consumer and the taxpayer, with its costs mainly met by increased consumer water bills. The construction of the project will both foster and pre-empt engineering and tunneling resources.

All that said, the optimal ranking of the relative macro-economic worth of competing projects is difficult to achieve in practice for many reasons.

These include the complexity of the wider policy environment in which the selection and prioritisation takes place; the related need to balance competing multiple objectives; the existence of contingent political pressures favouring some projects for reasons other than their economic and overall worth, as well as capacity constraints within the public sector to apply effectively project appraisal methodologies, which like all economic tools are also only as robust as their underlying assumptions allow them to be.

It is vital, nevertheless, that the institutional environment in which both economic and social infrastructural projects are planned, selected, and delivered is improved in step and consistent with fiscal reform.

The NIC should, therefore, be empowered to assist each government department to publish a required annual Departmental Investment Plan (DIP).

Each DIP should prioritise projects according to their estimated economic and social return, incorporating auditable information on the methodology applied to rank projects, according to their expected whole project-life return.

The IPA should also be specifically tasked and resourced to expand the pool of personnel skilled and experienced enough to conduct the project appraisals underpinning DIP’s.

Partnerships with universities and the private sector should develop the methodological base and to enlarge and deepen the skill set of appraisers.

Progress towards such an improved fiscal and institutional environment should foster efficient public planning and programming of projects and a greater degree of partnership planning between the public and private sectors.

Improved growth and productivity outcomes, balanced in income and spatial distributional terms, should follow.

But, even with their adoption, the sheer scale of future infrastructural funding requirements requires alternative and innovative public funding mechanisms.

Tackling the root causes of the rising relative real cost of providing of productive economic and social infrastructure.

The costs of providing infrastructural investment have escalated much faster than general inflation: the public investment relative price effect. The escalating cost of land as a component of housing investment since 1955 is a striking instance of its operation and effect.

The true fiscal crisis should also be recognized: the demand and need for productive public expenditures across both current and capital budgets will inevitably outstrip public willingness to pay through efficient and salient sources of taxation, at least within a current competitive political system focused mainly on the electoral short-term.

Overcoming that crisis, therefore, requires further concerted and systematic institutional and policy reform. Lateral, radical thinking across the political spectrum, capable of fostering an overlapping consensus, is required, as much as is incremental reform.

In that light, Sectoral and Departmental infrastructure strategies should identify, address, foster, and integrate joined-up policy efforts to make public investment less costly in net public expenditure terms.

Housing provides a case-in-point example where market failure and rent-capture unnecessarily increases the cost of provision. These should be identified and addressed directly, along and innovative public funding mechanism,  within the DIP process.

The most direct and effective way of reducing the public cost of affordable provision is by deflating its land value component. This could be done by a mixture or combination of measures focused on ensuring that the land value of affordable housing sites are limited to existing use value plus an agreed premium of, say, 30%, backed up by stronger compulsory purchase powers and an affordable housing obligations system that is more robustly, transparently, and uniformly applied than at present.

In parallel, the future long-term rental income and sales of a steady-state affordable housing programme could be securitised to provide collaterised backing for its public funding.
At an overarching level, a dedicated funding intermediary that could take equity stakes in economic and social infrastructure, where long-term returns (for example, linked to revenue streams, such as rents rising with inflation, interest on loans, profit-shares) could be realized and recycled across the lifetime of the project.

Links follow to the  A Social Democratic Future‘s full  Response to Treasury consultation June 2019, its Appendix Table 1, and a summary of the Recommendations.

The major issues that will need to underpin future assessments of the whole-life project efficiency of conventional and PPP projects are outlined in Table 1.

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Filed Under: Macro-economic policy Tagged With: housing, Investing for the Future, NIC

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