The 2013 UU/Cambridge research report made fairly detailed proposals for ‘banding’ of the applicants on the waiting list. The 2017 DFC consultation proposed “a hybrid system of points and bands” (p 19) which in theory would prioritise households on similar points but with longer waiting times – potentially welcome to many. However, the examples offered in the UU paper also raised other households up the bands, such as those with low housing need but which were seeking to downsize to something smaller, thereby ‘freeing up’ their current home; this would be a deeply concerning dilution of the commitment to allocating housing on the basis of objective need.

The DFC’s 2020 EQIA of the banding proposal noted a “possible adverse impact for those with high housing need, who have not been waiting a long time” but did not recommend mitigations. The 2020 Outcomes Report focused on operational concerns. It announced plans for independent research to lay the groundwork for implementation of banding, including “significant system and IT changes” (p. 59). No such independent research has been made public.

For all of these reasons, implementation will bear close watching going forward – in the interest of fairness to people in housing need, and to safeguard the principle of allocating social homes on the basis of objective need, which has already been waived in some areas on the recommendation of the Fundamental Review of Allocations.

One of these areas is ‘difficult-to-let’ properties, generally by definition ones located outside of areas of high housing need, where allocations are not dictated strictly by points but by who is willing to take up the property. Since implementation of FRA recommendations, social landlords are permitted to make multiple offers to “as many applicants as they think necessary” to try to fill a “difficult” vacancy, and to proceed directly to this step “if they have evidence that a property will be difficult to let”.

Similarly, choice-based letting has been introduced for a limited number of properties outside of areas of high need; these are available via a dedicated Housing Executive Property News page online. Choice-based letting is an alternative allocations system to the usual ‘direct letting’ used here. The 2013 UU/Cambridge research described it as:

“‘bottom up’ in nature. Applicants become actively involved in property selection and, more importantly, in the allocation process by matching themselves to a property and then making an expression of interest in that property, thereby exercising their right to choose” (p. 43).

At that time the academic researchers had proposed that choice based letting be rolled out for all social homes.

Both the ‘difficult-to-let’ and ‘choice-based lettings’ changes, PPR’s 2017 consultation response pointed out, set up workarounds to the points system that “subvert the principle of objective need”

Both the ‘difficult-to-let’ and ‘choice-based lettings’ changes, PPR’s 2017 consultation response pointed out, set up workarounds to the points system that “subvert the principle of objective need” (para. 14). The DFC’s 2020 EQIA, for instance, admitted that the changes “may increase the likelihood and speed of allocation for applicants in lower housing need” (pp. 23-24) -- but found no adverse impacts and recommended no mitigations. Once again, as the DFC’s 2020 consultation Outcomes Report made clear, “good housing management and better use of stock and resources” (p. 75) trumped allocating homes on the basis of objective need.

These precedents are the reason that implementation of the “banding” proposal will need watched so closely. If the DFC had adopted the UU / Cambridge research proposal for the establishment of a Strategic Independent Allocations Scrutiny Panel (pp. 69-74), we could at least have confidence that there was independent oversight of any changes to policy and practice, and people impacted by such changes would have somewhere independent to go for review and potential recourse. But this was one recommendation that housing authorities chose to ignore – to everyone’s detriment.

PPR’s full analysis of the ‘Fundamental Review of Allocations’ changes is here