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What will housing look like at Christmas 2014?

<strong><span class="has-inline-color has-accent-color">Steve Hilditch</span></strong>
Steve Hilditch

Founder of Red Brick. Former Head of Policy for Shelter. Select Committee Advisor for Housing and Homelessness. Drafted the first London Mayor’s Housing Strategy under Ken Livingstone. Steve sits on the Editorial Panel of Red Brick.

Just published on the Labour Housing Group website is a fascinating article by LHG Executive member Graham Martin, who tries to predict what will happen to the 3 main tenures between now and Xmas four years hence, when we will be 5 months away from the most likely date of the next General Election.  What will the Labour Party, when returned to government, be facing in housing?  Here is a summary of Graham’s conclusions (figures are for England only).   

Social Housing

Housing Associations currently own around 2.3m affordable homes.  Given the size of the stock, the overall numbers will change slowly despite the planned changes. 

  • The current (inherited and new) social rented programme will produce about 100,000-120,000 extra ‘target rented’ properties.  But between 100,000-170,000 existing target rent homes will be relet at intermediate (upto 80% market) rents.  In 2014 it is likely to be 50,000 fewer in total than now.
  • There will be around 285,000 more homes let at intermediate rents (say 135,000 relets and 150,000 new build). 
  • The debt funded/rental cross-subsidised new Intermediate rented homes will be produced mainly in London and the South East (with some in the South West and Midlands) as it is here that the maths work best.  In other parts of the country, intermediate rents will result in either a small increase or even a rent reduction, making development on the new model unviable. 
  • The biggest impact is likely to be caused by the interaction of the various benefit changes, and in particular the overall benefit cap of £26,000, restricting tenants’ ability to pay.

Council house numbers will change slowly.  There is little appetite and resources for significant stock transfers.  Some other conclusions: 

  • The reform of Housing Revenue Accounts is likely to improve councils’ financial strength and their ability to invest in their own stock.  There is a risk that there will be a smash and grab raid on HRA money (rising rents, financially more secure) to cross subsidise the General Fund.
  • The provision by councils of Intermediate rented housing is likely to be slow.
  • Management issues around benefits are likely to be the same as with Housing Associations.
  • Changes to statutory homelessness rules, and changing letting priorities will have a significant impact.

Home Ownership

Graham projects that house prices might fall another 20%, maybe 25%-30%, as measured against inflation. This will be mainly due to the long term ‘deleveraging’ of the residential mortgage market – i.e. there will not be the money to lend to home owners to buy new homes (such money as there is will go mainly to those buying the nicest properties with the biggest deposits).

Home construction for home ownership will be remain low until 2014, after which is may start to increase again (from a very low base).

The lack of affordable homes for (all but the best off) first time buyers will result in increased pressure on the rental market, and more adult children living in the parental home.

Private Rented Sector

The hardest to predict. The only certainly is that there will be big change.

The changes to Housing Benefit (and total benefit) rules will profoundly impact on the sector. Landlords may split their properties into smaller flats to respond to the benefit caps and ceilings.  Savills are projecting that the impact will be, first, large falls in demand for and rents of 1 bedroom flats (due to under 35’s now being subject to the ‘single room rate’ rule), and, secondly, increased demand for larger ‘shareable’ properties.

The new 30% centile cap on maximum HB and the plan to greatly widen the ‘Broad Market Rental Areas’ will have a big impact.  There are areas where over 30% of private tenants are dependant on HB, but will be constrained to living in the 30% of cheapest properties. 40% into 30% just does not go….

It is likely that the gap in housing (especially ‘green’) quality between other tenures and the private rented sector will grow significantly upto 2015.

Regulation and quality control are likely to be drastically reduced due to spending cuts, and there is a danger that undesirable landlord practices will increase. This is unfair to tenants but also to responsible landlords and managing agents.

There is an opportunity to promote high quality institutional landlordism, with investment available if the regulatory structure is right.  REITS – Real Estate Investment Trusts – could work well in residential letting, kick starting the UK residential construction industry, and providing high quality, long  term rented property at market rents.

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It just may not work

A lot of this blog has been dedicated to the effects of the government’s reforms to housing, local government and regeneration. We’ve built up a fair picture of the impacts of these reforms on communities and especially those on low incomes or in need.
But have we neglected something obvious: these rapid and dramatic reforms might just not work. I don’t mean that they may have consequences the government hasn’t foreseen but rather they may entirely unoperational for the various bodies that are supposed to enact them. Or interact in such a way that the (affordable) housing system just fails.
I have been vaguely thinking this but Vince Cable’s latest indiscretions, brought it to the fore. He’s quite clear of the possible impacts of the speed and extent of change:

There is a kind of Maoist revolution happening in a lot of areas like the Health Service, local government, reform, all this kind of stuff, which is in danger of getting out of… We are trying to do too many things, actually. Some of them are Lib Dem inspired, but a lot of it is Tory inspired. Actually, the problem is not that they are Tory-inspired, but that they haven’t thought them through. We should be putting a brake on it.

So what might a systematic failure in the housing system look like. A few initial thoughts:
1. Housing associations going bust, potentially caused by a combination of:

  • Housing associations over extending themselves (again), either through their own folly or the HCA/government trying to force too many new units out of the ‘investment agreement’ process.
  • Higher 80% rents which aren’t covered by housing benefit/universal credit creating spiralling bad debt, especially as councils maintain allocations policies of putting the poorest and neediest first (the irresponsible bureaucrats that they are) and housing associations not having the stomach or the ability to evict those that can’t pay.
  • Unstable and increasing borrowing costs and especially changes to the  existing loans that housing associations have – ramping up their existing debts, not even future ones.

2. Housing associations being reclassified as public bodies.
It may seem smart now for ministers to pontificate on CE pay or demand public sector-levels of transparency. It won’t look so smart if the ONS decide housing associations are public bodies and stick their debt on the public balance sheet. the Treasury I guess would stop all borrowing at once to protect the deficit reduction plan and a swift and full privatisation would likely follow. Who knows what mess would fall out of that.
3. A botched HRA reform:
You may have picked up that I’m broadly supportive of the HRA reform as it stands, but I wouldn’t put it past this government to engage in some last minute political meddling – a level of debt councils can’t support or an attempt to skew the debt to help Tory areas, as we saw in the local government finance settlement. This could see House Revenue Accounts going into the red, needing to be topped up from already diminishing council coffers and/or spending on maintenance and management stopping.
4. Planning reform that stops anything being built
This could be because either the policy impact of the Localism Bill does this or because the change and upheaval stops everything dead for a while. Housing, affordable and otherwise, completely grinds to a halt for years to come.
Update: It just occurs to me that of course in a lot of ways the housing system is already systematically failing. Perhaps I mean a failure in such magnitude or of such speed that requires immediate emergency action – such as the action which was taken during the crash to keep the existing system (and its flaws) going.

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Devolution in Three Acts

Steve’s previous post on HRA reform got me thinking about the government’s claims to devolution and decentralisation.
It seems to me the government’s measures fall into three categories: new centralism, devolving bad news and genuine decentralisation.
New centralism:
Any issues that are high on the government’s agenda are being centralised. Gove’s school reforms take more power and influence away from elected local councils over education. Welfare equally could have been localised or at least adapted to different local circumstances. But being high on the Tory agenda they keep it to themselves. Equally, populist measures like bin collections and banning council magazines are subject to central edict.
Devolving bad news:
So local authorities lose ring fencing at a time of the worst ever local authority cuts – meaning they have the ‘power’ only to decide what to cut. Council tax benefit gets localised, at the same time the government topslices 10% of it, without reference to need. Plenty of examples of this.
Genuine Decentralisation:
The new powers that social housing landlords have over rents and tenancy lengths constitute a genuine loosening of controls from the centre. But, the most extensive of these powers will be exercised by housing associations which may be national in scope and not subject to democratic accountability – so decentralisation yes, but localism or greater democracy?. The HRA reform (I think) is probably the only straight forward and genuinely localist reform so far: it devolves real control (and control over money at that) to a local democratic body.
I am surprised they have gone ahead with the reform given how everything has been sacrificed to deficit reduction. I thought any system which delivered a surplus to the Treasury would be very likely to stay put.
Any other categories of localism I’ve missed, or things I should add?

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One cheer and one HuRrAh

<strong><span class="has-inline-color has-accent-color">Steve Hilditch</span></strong>
Steve Hilditch

Founder of Red Brick. Former Head of Policy for Shelter. Select Committee Advisor for Housing and Homelessness. Drafted the first London Mayor’s Housing Strategy under Ken Livingstone. Steve sits on the Editorial Panel of Red Brick.

In trying to look beyond this government’s irksome habit of claiming credit for things agreed before the Election, at least it can be said that the snail’s pace move towards the abolition of the housing revenue account national subsidy system continues in vaguely the right direction. 

Having announced already that he planned to stick with most of John Healey’s proposals, announced it again as part of the November consultation on the reform of social housing, and announced it yet again as part of the Localism Bill package, Grant Shapps has now announced a ‘route map’  towards reform – in advance of a more detailed announcement next month!  The route map makes it clear that more detail will emerge over the next year before implementation in 2012, no doubt offering Mr Shapps further opportunities to announce his great, but inherited, reform.  Who said spin was dead?

Brought up on a council estate in Kenton, Newcastle, I have always had an emotional belief in council housing, and have often been outraged at the stigma attached to the tenure, the appalling media misrepresentations, and the snobbery.  Although what Thatcher did to council housing was unforgiveable, I was hugely disappointed that it turned out to be not very New Labour either.  But the rationale for council housing is not just emotive.  Based on a system of rent pooling, so that surpluses from older homes cross-subsidise the cost of new ones, it was also a robust financial model.  It could have provided hundreds of thousands if not millions of extra homes if it had been managed properly over the past 30 years.   

The Tories’ failure to invest in managing and maintaining the council stock left Labour with a huge problem in 1997, including a backlog of disrepair estimated at around £19billion and an incoherent rent policy.  Labour made some well meaning attempts at reform, such as the introduction of rent restructuring, the Major Repairs Allowance and the Decent Homes Programme, but funding for the latter carried the clear political price tag that direct management of the stock by councils was unacceptable to the government. 

As some councils in the national HRA subsidy system had large historic debts and others had none, the system was unbalanced and rent pooling became unmanageable.  It also became increasingly unpopular with tenants and councils in those areas where a third or even a half of local rents were taken for distribution elsewhere.  Despite producing growing surpluses nationally, all of the participants were unhappy with the outcome, even those that gained from redistribution.  As an annual system, there was no certainty about income and it was impossible for councils to plan long term and improve efficiency.  Tenants simply could not engage with the key decisions that affected their homes and communities because they were only understood by a tiny number of civil servants and professionals.  In its latter years, the Labour government became less hostile to the idea that council housing should have a long term future, and understood that a more local system suited the times.  It embarked on the hugely complex exercise of unravelling the system.

The Localism Bill contains powers to implement the local system proposed by Labour.  In future, councils will keep their rental income and use it locally to manage and maintain their own homes and service their debt.  To get to the point where all councils have sufficient income to meet these costs, there will be a one-off payment between central government and each council, which will reallocate existing housing debt between councils in a final settlement based on 30 year business plans for each landlord.  This is possible because the national system is in surplus – ie tenants are paying more in rent than council housing costs to run.

Communities and Local Government department’s task is complicated: they have to incorporate the implications of the new government’s shifting policies, for example on rents, as well as making important assumptions about inflation and the ‘discount rate’ (currently assumed to be 6.5%) used to determine the ‘net present value’ of each council’s housing business. 

I have 2 main concerns.  First, John Healey planned to allow councils to keep their right to buy capital receipts, whereas the Tories will retain the current system that returns 75% of net receipts to the Treasury.  There will also be a cap on councils’ overall housing borrowing.  Hope that HRA reform would trigger a resurgence in council housebuilding has been dashed.  The overall receipt to the Treasury from all the various calculations is currently projected to be around £6.5b, but tenants may come to view this as being paid for out of a large rent increase next year of over 7%.

Secondly, Labour would have localised the HRA within the clear framework of the regulatory regime.  There would have been an external check, through the Tenant Services Authority, and a place for tenants to go if, for example, their council set up backdoor arrangements that took funds out of the HRA to benefit the general fund.  It is still not clear how regulation will operate without the TSA, and this will make tenants in some areas nervous about what their landlords will get up to.   

At least we can look forward to further announcements.

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Principles for an early Labour housing policy

This is the follow on from my post the other day, arguing that Labour didn’t need housing policies now. But we do need to set out some principles to show how we’d be different and use as a basis for opposition to the government. Here’s my starter for 10, but are these too specific and prescriptive still?

  • Defend the principle that the state has a duty to ensure the poorest and most vulnerable are properly housed.

Under attack from the coalition a no brainer for us.

  • Promote the principle that the state has a role in ensuring the housing system meets everyone’s aspirations

The government should ensure that the private housing market and the mortgage market works better to meet what people want. And there should be a role helping those who aren’t the most vulnerable, but may struggle to buy, to have housing that meet their needs.

  • A commitment to mixed communities

 There are good policy reasons to ensure a mixture of incomes, class and ethnicities in a neighbourhood. It helps build understanding and solidarity between different types of people. And I believe the type of segregation you see in the US, France or elsewhere is culturally alien to us in Britain. For example, part of London’s identity has always been that rich and poor could live ‘cheek by jowl.’

  • Maintain some ‘Bricks and Mortar’ subsidy, i.e. grant to build affordable homes

The government has shifted financial support for those who can’t afford a home from building affordable homes (bricks and mortar subsidy) to housing benefit to allow people to pay private or near private rents (personal subsidy). This will be difficult even in five years’ time, but we shouldn’t give it up. Mixed communities depend on it and it means we support a wider range of providers.

  • A commitment to a mixed economy of housing; more products, more choice from more providers.

Labour should promote a more diverse sector: a wider range of private builders and more opportunities for smaller firms, more space for co-ops and mutuals, get more housing associations of different sizes building and free councils to build again. Encourage, support, cajole and compel providers to offer a diverse range of products from supported housing for those with extensive needs, to traditional social rents, to a variety of sub-market rents, to well managed professional private rent and a range of ways to get into homeownership.

  • Embrace localism; free councils.

Tricky this one. The government’s localism is a front for neglecting their responsibilities for ensuring everyone is well housed. But, support for new housing best comes from a local area and housing provision should respond to local needs, the type of community and people’s aspirations. One popular way would be to free councils to start building again and putting their housing business on the same footing as housing associations with the ability to borrow (someone with better knowledge needs to correct me as to why this is so impossible, as I’m often told). They should be able to build for a range of needs and aspirations and not just social rent. We will need to find a credible way to square this with 1. What happens when local areas make decisions that make it impossible to house everyone well?

  • Intervene to prevent another property bubble

If house prices ever start running away again, let’s be brave and act. And let’s tell people now that we will curb excessive house price rises. Making this argument successfully should be done immediately while the economic crisis is still fresh in people’s minds. You won’t convince homeowners just at the time when you need to do it that it’s needed.
There may be more things I think of…

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Localism Bill – the Pickle Family Circus

<strong><span class="has-inline-color has-accent-color">Steve Hilditch</span></strong>
Steve Hilditch

Founder of Red Brick. Former Head of Policy for Shelter. Select Committee Advisor for Housing and Homelessness. Drafted the first London Mayor’s Housing Strategy under Ken Livingstone. Steve sits on the Editorial Panel of Red Brick.

The famous American Pickle Family Circus was known for its ‘Big Juggle’ that ended every performance in an intricate club passing pattern.  As the Localism Bill, published yesterdy, passes ‘powers’ (ie the blame for cuts) down to councils, ‘Pickles Big Juggle’ seems an appropriate metaphor.

For social housing and homelessness, the Bill had few real surprises as everything had been widely trailed or pre-announced.  We’ll pick up on specifics in later posts but here’s an initial reaction to the Social Housing Reform chapter of the Bill.

On allocations, councils will be able to decide who goes on waiting lists, which will no doubt lead to great claims in the future about ‘cutting waiting lists’.  We will be back to local manipulation of the list for political ends.  Transferring tenants will be moved outside the waiting list, but there is no evidence to support the claim that this will make it ‘easier for them to move’.        

On homelessness, its a nerve to call this reform rather than virtual repeal.  Come on Shelter, time to wake up to what is actually happening here!   And come on LibDems, the homelessness legislation was a Liberal private member’s Bill in the first place, something the Party has always been proud of  – time for you to speak up.  The government complains that 20% of social lettings go to homeless people ‘at the expense of other people in need on the housing waiting list’.  A miserable and ‘divide and rule’ justification for an extraordinarily backward step. 

The introduction of ‘flexible tenancies’ (insecure fixed term tenancies) which will gradually turn social housing into transit camp accommodation.  Some housing association chief executives really like this, so I am even more concerned.   

Reform of council housing finance is something I welcome but we still have to be careful about how much will be returned to the Treasury and how the detailed formulae will apply to different councils with stock.  Called a ‘key plank of localism’ but a previous Labour measure. 

The proposed Homeswap Scheme again is something to welcome as mobility arrangements need a boost.  Landlords will be required to participate in home swap schemes. 

‘Reform’ of the regulatory system and abolishing the Tenant Services Authority will, in some magical and as yet unexplained way, “put local people in control of driving up standards of social housing management and resolving most failings.”  Social tenants will receive ‘stronger tools to hold landlords to account’ but I’ll believe it when I see it.  The more likely explanation lies in the statement that ‘State intervention will be reduced’.  A positive change will be to end the system of two separate ombudsmen handling complaints, providing a common route for all social housing tenants.

In London, new powers for the Mayor will include full control over housing investment, a good step, and the devolution of more planning decisions to the boroughs.

Watch this space for more discussion of these issues over the coming few weeks.

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Council cuts hit most deprived hardest

<strong><span class="has-inline-color has-accent-color">Steve Hilditch</span></strong>
Steve Hilditch

Founder of Red Brick. Former Head of Policy for Shelter. Select Committee Advisor for Housing and Homelessness. Drafted the first London Mayor’s Housing Strategy under Ken Livingstone. Steve sits on the Editorial Panel of Red Brick.

Did anyone really believe it when the coalition claimed to be ‘progressive’ and that it would stand up for the worst off in society? The local government cuts are an extraordinarily clear example of the vindictiveness of the government and its wholly political approach to funding. Their motto should be ‘we look after our own’.

Where do the biggest cuts fall? From South Tyneside, Sunderland and Hartlepool in the north east to Southwark, Hackney and Tower Hamlets in London, those getting the biggest cuts of over 8% read like a list of the most deprived communities in the country. And who does well? Little surprise here as well. It’s Dorset, Kent, Bucks and the Tory shires. You can get figures for all councils here.

If the division isn’t strictly political, there is a clear inverse correlation between the size of the cuts and the level of deprivation.

Nationally, the LibDems seem to be getting all the flak while hard core Tory policies just steamroller through. Even if they support cuts of this scale, surely they don’t support this distribution between councils?

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Labour doesn't need a housing policy yet

There seem to be some calls for Labour to have a worked out housing policy as an alternative to the government’s now.
That would be a daft move.
It’s four and a half years to the next election and the government is starting the most radical process of reform to housing in a generation. Whether these reforms are successful in their own terms or not, the housing system will be very different when Labour next has a chance to implement an alternative (I assume that the Coalition will run the course).
Writing a housing policy that’s credible now is unlikely to work five years on. And trying to write a policy for five years’ time requires too much guess-work and will sounds out of touch now.
Ed Miliband and Alison Seabeck are absolutely right to wait, think and develop their ideas.
So, in the long meantime, how do we oppose the government? Here’s what I think:

  • Firstly, we take the government at their word and hold them to it.

The government has some laudable rhetoric: to build more mixed communities, to build more homes and more affordable homes, to tackle worklessness in social housing, to make it easier to move within social housing. Let’s exploit the differences between their words and the effects of their policies.

  • Secondly, avoid falling into any elephant traps that we live to regret, especially promises to reverse particular measures.

Reinstate security of tenure? Cut rents back to ‘traditional’ social rent? Restore the duty to house the homeless in the social sector? They might sound great ideas now, but on entering office, they probably won’t be so attractive. The future businesses of housing associations are likely to be built on these measures, as will housing provision by local authorities.
Do we want to re-enter office with pledges that immediately threaten the basis of our main housing providers? No, we don’t.  And this path leaves us the defenders of a status quo which had some pretty serious faults. Needless to say that’s not a winning position.

  • Set out the principles of a Labour housing policy, and one which is not beholden to what we have done in the past.

That’s the hardest task. I’ll give my starter for 10 in my next post.

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Odd effects

It’s no exaggeration to say that the changes that the government are introducing to affordable housing are the most extensive and far-reaching since 1945. They’re also implementing them at real pace.
That means they can’t really work through the impacts of what will happen on the ground when all these reforms start working together. Some of the effects are going to be pretty perverse, from what I hear from housing people. Here’s one:
In the private rented sector, families are going to be forced out of family-sized homes, and these same homes will become the preserve of single people.
Why?
1. The cap on housing benefit and the cap on overall benefits to £26,000, are likely to force larger families into smaller homes as family homes for them become unaffordable. There’s a strong chance that this measure will considerably increase overcrowding.  
2. The government’s reforms to single people’s benefits will give people under-35 enough housing benefit to afford a room is a shared home. So, as families stop being able to afford to live in family homes, private landlords will find it easier to let larger homes to several single people.
So, it would seem to the centre that these are consistent policies to reducing the benefits bill – imposing benefit limits on families and single people. On the ground, it creates the perverse situation where poorer families get forced out of family homes which are then colonised by poorer single people.
The Mayor of London and the government have said it’s a problem that there are not enough family homes for families and we don’t build enough of them. It’s true. But, family homes in the private sector for poorer people are going to become more scarce.

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In praise of Ken (and maybe Boris)

<strong><span class="has-inline-color has-accent-color">Steve Hilditch</span></strong>
Steve Hilditch

Founder of Red Brick. Former Head of Policy for Shelter. Select Committee Advisor for Housing and Homelessness. Drafted the first London Mayor’s Housing Strategy under Ken Livingstone. Steve sits on the Editorial Panel of Red Brick.

Feeling (uncharacteristically since May) in a positive frame of mind, I had planned three posts this week all of which intended to say something good about government policy.  It was only after some cogitation that I realised all three of the ideas I liked were leftovers from Labour administrations but I am willing to give credit where it is due if the coalition picks up and implements sensible reforms.  Unfortunately, of the three – Boris Johnson’s plans for social housing mobility in London, the council housing finance proposals, and strong steps towards encouraging mutualisation in housing – the latter two announcements have been deferred with the Localism Bill from this week until a point in the future.  I certainly don’t feel able to commend the coalition until I’ve seen confirmation of the plans in writing.

So, for the moment, that leaves Mayor Johnson and mobility for social tenants, which will hopefully be a precursor to improvements in mobility for tenants nationally as well.  His consultation paper, introduced in the Mayor’s usual combative style, can in fact be sourced back to Mayor Livingstone’s housing strategy.  Of course, Johnson eschews the opportunity to highlight a bipartisan measure in favour of trying to take all the credit for himself.

Livingstone’s approach to mobility had two drivers in addition to the principle that more mobility for social tenants was a good thing in itself.  First, The London Plan had a major focus on redeveloping swathes of east London where very large housing sites were available and there were huge opportunities to create sustainable new communities (including the Olympic sites).  But if a large and increasing share of London’s available capital resources went to support new affordable homes in only a few boroughs, a mechanism had to found to ensure that the benefits of new development were more widely shared amongst Londoners as a whole.  

Existing sub-regional arrangements, good in themselves, were not enough and a pan-London mobility scheme, starting with a share of new development and growing gradually to take in a share of re-lets across the capital, became an essential element of the Plan.  Secondly, Livingstone identified a particular problem with wheelchair standard and other homes adapted for disabled people.  Frequently such homes were being let to people not in need of them whilst others in dire need were not eligible because they did not live in the same borough.  A wider geographic system and pan-London register of dwellings and households was needed to make best use of these scarce resources.  

These are good examples of circumstances where localism is not enough and a wider area or regional approach is essential for good policy.  Anyone reading the consultation paper will be struck by how complex it can be to achieve a balance between local, sub-regional, regional and cross-regional needs. 

The consultation paper shows some concern that the government’s proposals on tenure (with much more flexibility given to landlords to vary the length and terms of some tenancies) will make mobility schemes harder to operate: users are already often bewildered by the complexity of existing schemes.  And it is also sensible in arguing that the scheme should not incorporate much by way of ‘conditionality’ – such as a requirement that tenants moving must be in or accessing work or training.  

Overall, it must be said, the consultation paper shows little actual progress since Johnson took over, now 2 ½ years ago.  Livingstone had put in place the necessary requirements on landlords as part of the 2008-11 London affordable housing programme.  We should be well beyond the stage of a consultation paper.  The paper itself is still aspirational in tone and a long way from real fruition.  It may be that it will not be implemented until Mayor Livingstone is back on the throne in 2012.

Mobility for London’s social tenants: An HCA London Board Consultation, December 2010.

http://www.london.gov.uk/sites/default/files/Mobility%20for%20London%27s%20social%20tenants%20-%20consultation%20December%202010.pdf