Craft Policies

Proposal

The full proposal, chapter by chapter. Select a heading to read its source section.

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Chapter 1 Executive Summary

1Overview

The central proposal: public land, manufactured construction and investment bonds combine to deliver affordable homes.

1.1Public Land at Peppercorn Lease

Land accounts for 30–80% of UK house prices.

1.2Modern Manufactured Construction

The Trust specifies a performance standard and a price, and tenders the construction to whoever can meet them: WikiHouse microfactories, volume…

1.3Housing Investment Bonds

Construction is funded not through public borrowing or private mortgages but through a new tradeable bond paying a fixed real coupon of 3%, adjusted…

Chapter 2 Who This Is For — The Target Cohort

2Overview

The households the scheme serves, the income-based affordability rule and the distinction between the pilot and lower-cost cases.

2.1Justification for a £75,000 Upper Boundary

At £75,000 gross, a household can in theory purchase a median-priced home in England — but only at the national median price, only with a 10% deposit…

Chapter 3 The Home — and Who Builds It

3Overview

The home specification, WikiHouse reference design, competitive tender, construction payments and quality protections.

3.1What Is Being Proposed

The Trust is proposing a performance specification and a price, not a construction system.

3.2The Reference Design: WikiHouse Switch House

The specification in 3.1 can be met by several systems.

3.3How a Home Gets Built

The process from factory to occupancy has four stages, whichever system the successful bidder uses.

3.4Who Builds: Competitive Tender

The Trust does not build.

3.5Paid in Cash, From the Bonds

The successful contractor is paid in cash, at each certified stage of the works, from the proceeds of the Housing Investment Bonds issued for that…

3.6Why the Builder Owns Nothing

The contractor is paid in cash for its work.

3.7Retention and Defects

A retention of 5% of each certified sum is held in cash in the ordinary way: half released at practical completion and half at the end of the…

3.8What This Does to the Price

Appendix VI’s indicative all-in figure for a Switch House is £125,000 to £145,000, and it is tempting to read that as a build cost with comfortable…

3.9What Is Not Being Proposed

These are not temporary structures, prefabs or containers.

3.10What Else the System Can Build

The Switch House is the reference design because the most acute housing need is among families.

Chapter 4 Housing Investment Bonds — Who Invests and Why

4Overview

The intended investors, inflation-linked returns, repayment, trading and the proposed tax treatment.

4.1The Investment Opportunity

The UK is short between 4.3 and 6.5 million homes.

4.2Who Invests

The bonds are designed for four classes of investor.

4.2.1Institutional Investors

Pension funds, insurance companies, and local authority pension schemes are required by their liability structures to hold long-duration,…

4.2.2Retail Investors

Individual savers accessing the bond through investment platforms and apps receive a predictable, inflation-protected return with a transparent social…

4.2.3Fractional Investors

The bonds are issued in £100 units, because an ISA can hold a whole bond but not a fraction of one: the ISA Regulations were amended in 2024 to admit…

4.2.4Ethical and Impact Investors

A growing segment of the investment market — both retail and institutional — operates under mandates requiring measurable social returns alongside…

4.3What Investors Get

What Investors Get

4.3.1A 3% Real Return

The coupon is fixed in real terms and adjusted annually for CPI: a 3% real return is, at 2% inflation, a nominal return of about 5% a year, and the…

4.3.2Tax-Free Income Within ISA

Interest earned within an ISA is entirely free from income tax and capital gains tax under the ISA Regulations 1998.

4.3.3Liquidity

Bonds are tradeable on a secondary market — the bond does not require a 35-year holding period.

4.3.4Low Risk

Occupancy risk is minimal in a market structurally short of millions of units.

4.4The Case for Full Tax-Free Status

Beyond ISA eligibility, a case exists for statutory tax exemption on bond interest, following the precedent of NS&I Premium Bonds and NS&I Fixed…

4.5What the Government Provides — and What It Gets Back

The government's contribution to the bond framework is land, legal framework, and tax treatment.

4.6Required Structure

The operational architecture for bond issuance, fund management, rental collection, and bondholder distribution requires detailed design work beyond…

Chapter 5 How the System Works

5Overview

The full route from public land and bond finance to construction, occupation, repayment and reinvestment.

Chapter 6 The Scale of the Problem — Problem Statements

6Overview

The housing shortage, limits on construction and lending, affordability pressures and the public cost of inaction.

Chapter 7 Land — What Exists and the Legal Barriers to Peppercorn Rents

7Overview

Public land availability, peppercorn leases, existing disposal requirements and the changes needed to enable the programme.

7.1What Is Available

Central government holds approximately 299,000 hectares.

7.2The Current Model

Public land is sold at market value.

7.3What This Proposal Does Instead

The government grants a long lease at peppercorn rates, retaining the freehold of the land in perpetuity.

7.4Legal Framework

Four areas of law govern the disposal of public land at below market value.

7.4.1Section 123, Local Government Act 1972

Local authorities must obtain "the best consideration that can reasonably be obtained" when disposing of non-housing land.

7.4.2Sections 32 and 43, Housing Act 1985

Land held by local authorities for housing purposes is subject to a separate, stricter regime.

7.4.3Managing Public Money (HM Treasury)

Central government land is subject to Treasury rules requiring disposal at market value.

7.4.4Subsidy Control Act 2022

Leasing public land at peppercorn rates to a delivery body that lets homes at below-market rents is likely to constitute a subsidy under the Act.

7.5Summary of Required Changes

All four barriers can be resolved without primary legislation:

Chapter 8 Planning

8Overview

The planning route for the pilot, the limits of existing consent mechanisms and options for faster national delivery.

8.1Consent Is Not the Binding Constraint

It is tempting to call planning permission the single largest source of delay, cost and uncertainty in UK housebuilding, and to ask for a fast-track…

8.2The Ordinary Route and Its Limits

Planning permission is still a real cost and a real delay, and the proposal should not pretend otherwise.

8.3The Nationally Significant Infrastructure Route

For energy, transport, water, and waste, the problem of local veto was solved by the Planning Act 2008 (PA 2008).

8.4Housing Is Excluded by Statute

Housing cannot use this route.

8.5What Would Make a National Programme Faster

There are three routes to a faster consent for qualifying developments.

8.5.1Route 1: Amend the Planning Act 2008

Repeal section 35(5) of the PA 2008.

8.5.2Route 2: Create a Housing-Specific Fast-Track Planning Route

Rather than fitting housing into the existing NSIP regime, create a parallel fast-track consent process for qualifying affordable housing schemes —…

8.5.3Route 3: Dedicated Primary Legislation

Enact a standalone statute — an Affordable Housing (National Infrastructure) Act — that designates bond-funded affordable housing on public land as…

8.6What This Proposal Does — and Does Not — Do to Local Planning

None of these routes abolishes local planning.

Chapter 9 Equality Act 2010

9Overview

The allocation policy, its effects on different groups and the proposal’s equality justification and assessment duties.

9.1The Issue

The eligibility criteria for this scheme — household income between £31,500 and £75,000 gross, with at least one member in employment — define the…

9.2Who Is Disadvantaged

Three groups are placed at a particular disadvantage by income and employment criteria.

9.2.1Disabled People

The employment rate for disabled people in the UK is approximately 53%, compared to approximately 82% for non-disabled people (DWP, Family Resources…

9.2.2Women

Women are over-represented in part-time employment (ONS, Labour Force Survey) and in lower-paid occupations.

9.2.3People Economically Inactive or Benefit-Dependent

While "benefit claimant" is not itself a protected characteristic under section 4, benefit dependency correlates with disability, caring…

9.2.4Race and Ethnicity

Unemployment among Black, African, and Caribbean people in the UK is approximately 7%, compared to 3% for White British people (ONS, Labour Market by…

9.3The Justification

Section 19(2)(d) provides a complete defence to indirect discrimination where the PCP is a proportionate means of achieving a legitimate aim.

9.3.1Legitimate Aim

The aim is to address a specific, documented failure in the housing market: the absence of any adequate provision for working households earning…

9.3.2Why Broadening Eligibility Would Defeat the Aim

The scheme operates within a finite housing supply — 500 homes in the proof of concept, scaling thereafter.

9.3.3Existing Provision for Excluded Groups

The proportionality of the exclusion depends in part on whether alternative provision exists for those excluded.

9.3.4Proportionality

The means are proportionate because the exclusion is no wider than necessary to achieve the aim.

9.4The Public Sector Equality Duty

Section 149 of the Equality Act 2010 requires public authorities, in the exercise of their functions, to have due regard to the need to eliminate…

Chapter 10 Building Regulations and the Building Safety Act 2022

10Overview

The home’s regulatory requirements, safety, thermal performance, warranty, maintenance and hazard response.

10.1The Regulatory Framework

This chapter demonstrates compliance for the reference design, the WikiHouse Skylark Switch House, because it is the benchmark every tender is judged…

10.2The Building Safety Act 2022: Higher-Risk Buildings

The Building Safety Act 2022 (c. 30) established the Building Safety Regulator within the Health and Safety Executive (section 2).

10.3Compliance with Schedule 1: Part by Part

Compliance with Schedule 1: Part by Part

10.3.1Part A — Structure

Requirement A1 of Schedule 1 provides that the building shall be designed and constructed so that the combined dead, imposed and wind loads are…

10.3.2Part B — Fire Safety

Requirements B1 through B5 of Schedule 1 address means of warning and escape (B1), internal fire spread — linings (B2), internal fire spread —…

10.3.3Part L — Conservation of Fuel and Power

Requirement L1 of Schedule 1 provides that reasonable provision shall be made for the conservation of fuel and power in buildings by limiting heat…

10.3.4Part O — Overheating

Requirement O1, introduced to Schedule 1 in June 2022, provides that reasonable provision shall be made in dwellings to limit unwanted solar gains and…

10.3.5Part F — Ventilation

Requirement F1 of Schedule 1 provides that there shall be adequate means of ventilation provided for people in the building.

10.3.6Parts C, E, G, H, J, K, M, P, Q, R and S

The WikiHouse Skylark system is a structural chassis — a superstructure to which external cladding, internal finishes, windows, doors, services,…

10.4Embodied Carbon and Lifecycle Performance

The Loughborough University life cycle assessment found that a WikiHouse dwelling produces less than half the lifecycle greenhouse gas emissions…

10.5Structural Warranty

A 10-year structural warranty is not a legal requirement for new dwellings.

10.6What This Means

The Building Regulations set performance standards.

10.7Awaab’s Law

Awaab Ishak died in December 2020, aged two, from prolonged exposure to mould in a social rented flat in Rochdale.

10.8Summary of Applicable Legislation

AreaPrimary Legislation / RegulationBuilding RegulationsBuilding Act 1984, ss.1, 6, 7, 91ZA; Building Regulations 2010 (SI 2010/2214), regs 4, 7, Part…

Chapter 11 Community Infrastructure Levy, Section 106, Biodiversity Net Gain, and VAT

11Overview

CIL, Section 106, biodiversity, nutrient neutrality, drainage and VAT: how development requirements affect cost.

11.1Community Infrastructure Levy

The Community Infrastructure Levy (CIL) is a charge that local planning authorities in England may levy on new development to fund infrastructure.

11.2Section 106

Section 106 of the Town and Country Planning Act 1990 (TCPA 1990) provides that a person interested in land may enter into a planning obligation by…

11.3Biodiversity Net Gain

Section 98 of the Environment Act 2021 (c. 30) inserted a new Schedule 7A into the TCPA 1990, which requires that planning permissions granted in…

11.4Nutrient Neutrality

In catchments draining to designated habitats (principally Special Areas of Conservation and Special Protection Areas under the Conservation of…

11.5Sustainable Drainage Systems

Schedule 3 to the Flood and Water Management Act 2010 (c. 29), if commenced, would require new developments to include sustainable drainage systems…

11.6VAT

The construction of new dwellings is zero-rated for VAT under Group 5 of Schedule 8 to the Value Added Tax Act 1994 (VATA 1994).

11.7What This Means for Cost

The environmental and planning obligation costs for this scheme are real but substantially lower than for conventional market housing, for three reasons.

Chapter 12 Governance — The National Affordable Housing Trust

12Overview

The charitable Trust, its governance, tax position and the legal protections intended to retain the homes.

12.1The National Affordable Housing Trust

The scheme needs an institution that will outlast any government, any board, and any individual involved in creating it.

12.2Why a Community Benefit Society

A community benefit society (CBS) is a body registered with the Financial Conduct Authority under the Co-operative and Community Benefit Societies Act…

12.3Charitable Status

To qualify as a charity, the Trust must be established exclusively for charitable purposes (Charities Act 2011, s.1(1)(a)) and those purposes must be…

12.4Governance

The Trust’s rules — the governing document for a CBS — will provide for a board of at least seven trustees, including a minimum of two with relevant…

12.5Tax Treatment

The tax position of a charitable CBS is one of the strongest arguments for the structure.

12.6Why the Homes Stay Where They Are

Chapter 4.5 says that the asset never leaves public ownership.

12.6.1Statutory Enfranchisement

A long residential lease ordinarily carries statutory rights to acquire the freehold or an extended lease: for houses under the Leasehold Reform Act…

12.6.2A Future Right to Buy

The second threat is political, and it is the one the asset lock cannot meet.

12.6.3The Ban on New Leasehold Houses

The third threat is statutory and prospective.

12.7Summary of Applicable Legislation

AreaPrimary Legislation / RegulationSociety registrationCo-operative and Community Benefit Societies Act 2014, s.2(2)(a)(ii), s.83Exempt charity…

Chapter 13 Housing Investment Bonds — Structure and Issuance

13Overview

Bond terms, progressive repayment, investment channels, inflation linking and the order in which rent is applied.

13.1Bond Parameters

Each development is funded by the issuance of Housing Investment Bonds.

13.2Why Amortising, Not Bullet

This is a design choice with consequences.

13.3Single Class, Three Channels

The Trust issues one class of bond per development.

13.4CPI Index-Linking

The bonds are linked to the Consumer Prices Index as published by the Office for National Statistics.

13.5Revenue Security and Payment Waterfall

The bonds are secured by a first fixed charge on the rental income of the specific development they fund.

Chapter 14 Regulatory Framework for Bond Issuance

14Overview

The issuance framework, prospectus strategy, retail access, ISA treatment and secondary-market arrangements.

14.1The New Regime

From 19 January 2026, the issuance and listing of bonds in the UK is governed by the Public Offers and Admissions to Trading Regulations 2024 (SI…

14.2Prospectus Strategy

The Trust will publish a base prospectus approved by the FCA, from which individual bond series are issued under final terms.

14.3The Trust Does Not Require FCA Authorisation

A point that may cause confusion: the Trust does not need FCA authorisation to issue its own bonds.

14.4Retail Designation and Product Disclosure

Two features of the 2026 regime bear on how the bonds are sold to individuals, and the first of them is a route that is closed.

14.5ISA Eligibility

If the bonds cannot be held in an ISA, the retail strategy fails.

14.5.1Qualifying Investment

The ISA Regulations 1998 (SI 1998/1870), as amended, define qualifying investments for a stocks and shares ISA.

14.5.2Innovative Finance ISA

As an alternative or complement, the bonds may also qualify for inclusion in an Innovative Finance ISA under ISA Regulations, regulation 8A.

14.5.3Denomination and Fractional Access

The natural design is for bonds to be held from £1 through fractional interests in a nominee’s holding, within an ISA.

14.6Secondary Market

The bonds have a 35-year term.

14.6.1Why It Is Required

The FCA’s product governance rules (PROD sourcebook) require that the target market assessment for any financial instrument considers the client’s…

14.6.2Where the Bonds Trade

The London Stock Exchange’s Order Book for Retail Bonds, launched in 2010, was decommissioned on 19 January 2026 alongside the new prospectus regime.

14.6.3Where the Initial Float Comes From

A secondary market needs sellers.

14.6.4Amortisation and Secondary Market Pricing

Amortising bonds trade differently from bullet bonds.

Chapter 15 The Prospectus

15Overview

The information disclosed about the Trust and bonds, sustainability reporting and responsibility for the prospectus.

15.3Sustainability Disclosure

If the bonds are marketed as 'social bonds', PRM 4.6 requires the prospectus to state this, describe the social objectives, explain the criteria for…

15.4Liability

Under POATR reg.37, persons responsible for a prospectus are liable to compensate investors for loss caused by untrue or misleading statements or…

Chapter 16 The Government’s Role at Proof of Concept

16Overview

The 500-home pilot, government’s initial bond purchase, public-finance treatment and subsequent investment exit.

16.1The Pilot

The proof of concept is 500 homes across ten sites, not the 100 across three that a cautious first step would suggest.

16.2What Government Buys

At proof of concept the primary bond purchaser is the government.

16.3Purchase Route

The purchase can be routed through several existing institutional channels.

16.4How It Scores

The distinction from a grant matters for fiscal classification, and it is easy to state too simply.

16.5Exit

Once the model is proven and the Trust has established a rental income track record — two to three years of full occupancy, audited accounts,…

16.6Summary of Applicable Legislation

The following table collects every Act, statutory instrument and regulatory sourcebook referenced in Part II of this document.

Chapter 17 Allocation and Tenure

17Overview

Eligibility, local connection, key-worker priority, allocation, the residential lease and residents’ protections.

17.1The Principle

The allocation process must be open, transparent and fair.

17.2Eligibility Criteria

Eligibility Criteria

17.2.1Income

Gross household income must fall within the range set by the rent arithmetic for the development in question.

17.2.2Contribution

The household must be a working household.

17.2.3Local Connection

The household must have a connection to the area in which the development stands, shown in one of two ways:

17.2.4Immigration Status

The applicant must have the right to reside in the United Kingdom.

17.2.5Criminal Record

An applicant with an unspent conviction for a serious criminal offence may be excluded from allocation.

17.3Key Worker Priority

Key worker status is not an eligibility requirement.

17.4Registration and the Nominations Framework

Registration and the Nominations Framework

17.4.1Why Register

The Trust will register with the Regulator of Social Housing as a registered provider of social housing under the Housing and Regeneration Act 2008,…

17.4.2Co-operation with Local Authorities

Registration brings the Trust within the Housing Act 1996, s.170, which requires a registered provider, where a local housing authority so requests, to…

17.5Allocation Process

The process is designed to be simple, auditable and resistant to discretion.

17.6.1The Thirty-Five-Year Lease

The Trust grants each household a lease of thirty-five years at a rent, with no premium.

17.6.2Rent

The rent is a single inclusive figure, fixed at grant by the arithmetic in Chapter 2 and adjusted once a year in line with CPI, as the bonds are…

17.6.3Renewal

At the expiry of the thirty-five-year term, the household has the right to a new lease for a further term of thirty-five years on the Trust’s then…

17.6.4Termination by the Trust

The grounds for possession in Schedule 2 to the Housing Act 1988 do not apply to the lease, because it is not an assured tenancy.

17.6.5Termination by the Household

The household may end the lease at any time on three months’ notice.

17.6.6Succession

On the death of the leaseholder, the lease vests in the personal representatives.

17.6.7Repairs

The Trust is responsible, by statute and by covenant, for the structure and exterior of the home and for the installations for the supply of water, gas…

17.6.8Subletting and Assignment

The lease prohibits subletting and prohibits assignment other than under 17.6.6.

17.6.9What the Household Cannot Acquire

A long residential lease ordinarily carries statutory rights to acquire the freehold or an extended lease.

17.7The Equality Act 2010

The Trust’s allocation policy does not select or exclude on the basis of any protected characteristic.

17.8Summary of Applicable Legislation

AreaPrimary Legislation / RegulationExclusion from assured tenancyHousing Act 1988, Sch.1, para 3D (as inserted by Renters’ Rights Act 2025, s.31, from…

Chapter 18 Subsidy Control

18Overview

The treatment of public support, the government bond purchase, contractor payments and the programme’s cost advantages.

18.1The Question

The government subscribes at par for approximately £105 million of Housing Investment Bonds at the Proof of Concept stage, as anchor purchaser (Chapter…

18.2The Subsidy Control Act 2022

The Subsidy Control Act 2022 replaced the EU State Aid regime with a domestic framework following the UK's departure from the European Union.

18.3Application to the Bond Purchase

Application to the Bond Purchase

18.3.1Public Resources

The government's purchase of approximately £105 million in bonds is financial assistance from public resources.

18.3.2Economic Advantage

This is where the argument begins.

18.3.3Specificity

The bond purchase benefits the Trust and no other enterprise.

18.3.4Effect on Competition

This requires more care.

18.4Compliance with the Subsidy Control Principles

Schedule 1 to the Subsidy Control Act 2022 sets out seven principles against which subsidies must be assessed.

18.4.1Principle A: Common Interest

"Subsidies should pursue a specific public policy objective in order to remedy an identified market failure or to address an equity rationale such as…

18.4.2Principle B: Proportionality

"Subsidies should be proportionate to their specific policy objective and limited to what is necessary to achieve it."

18.4.3Principle C: Behavioural Change

"Subsidies should be designed to bring about a change of economic behaviour of the beneficiary that (a) is conducive to achieving the objective, and…

18.4.4Principle D: Conditionality

"Subsidies should not normally compensate for the costs the beneficiary would have funded in the absence of any subsidy."

18.4.5Principle E: Appropriate Policy Instrument

"Subsidies should be an appropriate policy instrument to achieve a public policy objective and that objective cannot be achieved through other less…

18.4.6Principle F: Competition and Investment

"Subsidies should be designed to achieve their specific policy objective while minimising any negative effects on competition or investment within the…

18.4.7Principle G: Net Positive Effects

"Subsidies should not have negative effects on trade or investment between the United Kingdom and other countries that are disproportionate to the…

18.5The Comparison That Matters

Every significant housing intervention by the UK government in the past forty years has been a subsidy.

18.6Procedural Requirements

The Subsidy Control Act imposes procedural obligations that must be met before the bond purchase is made.

18.6.1Assessment

The granting authority — whichever public body authorises the bond purchase (the Treasury, MHCLG, or the National Wealth Fund) — must assess the…

18.6.2Subsidy Database

Subsidies above the minimal financial assistance threshold (£315,000 over three fiscal years per enterprise, per s.36) must be entered in the subsidy…

18.6.3Transparency

The subsidy database is publicly searchable.

18.6.4Challenge

An interested party may apply to the Competition Appeal Tribunal for a review of a subsidy decision (s.70).

18.7Note on the Market Economy Investor Principle

Under the previous EU State Aid framework, the Market Economy Investor Principle ('MEIP') provided that a public investment made on terms that a…

18.8Paying the Contractor

The construction contract raises a second subsidy control question, distinct from the bond purchase: whether the Trust’s payments to its contractor,…

18.9What the Trust’s Home Does Not Pay

The Home Builders Federation estimated in May 2026 that taxes, regulation and inflation had added about £76,000 to the cost of building a new home…

18.10Summary of Applicable Legislation

AreaPrimary Legislation / RegulationSubsidy definition and principlesSubsidy Control Act 2022, ss.2–4; Schedule 1Assessment dutySubsidy Control Act…

Chapter 19 Infrastructure — Roads, Utilities and Site Preparation

19Overview

Infrastructure funding, utility connections, roads and drainage adoption, site preparation and indicative costs.

19.1The Separation

The financial architecture of this scheme rests on a clean division.

19.2Which Grant

The Social and Affordable Homes Programme 2026–2036 is the primary capital funding programme for affordable housing in England: £39 billion over ten…

19.3Utility Connections

The statutory framework for utility connections is well-established.

19.3.1Water

The Water Industry Act 1991, ss.41–44 imposes a duty on water undertakers to provide a water main to serve new development where required.

19.3.2Electricity

The Electricity Act 1989, s.16 places a duty on electricity distributors to make a connection to premises when required.

19.3.3Gas

The Gas Act 1986, s.10 places a duty on gas transporters to connect premises to the gas network when required.

19.3.4Broadband

The Telecommunications Infrastructure (Leasehold Property) Act 2021 and the Product Security and Telecommunications Infrastructure Act 2022 strengthen…

19.4Roads and Drainage Adoption

Roads and Drainage Adoption

19.4.1Roads: Highways Act 1980, s.38

New estate roads serving the Trust’s developments are built to adoptable standards and offered for adoption by the local highway authority under the…

19.4.2Drainage: Water Industry Act 1991, s.104

The foul and surface water drainage system serving the development is built to adoptable standards and adopted by the sewerage undertaker (the local…

19.5Site Preparation

Site preparation costs vary enormously by site and cannot be modelled generically.

19.6Indicative Infrastructure Costs

The following table provides indicative infrastructure costs per 100-home development for three site types.

19.7What Infrastructure Does to the Rent

The pilot costing model in Appendix I.6 takes the midpoints of the table above, weights them by a site mix of 30% greenfield, 50% clean brownfield and…

19.8Subsidy Control: Serviced Land

Under the serviced-land route, the public landowner’s infrastructure spend is financial assistance from public resources and is assessed as part of the…

19.9Note on CIL and S106 Exemptions

As a registered provider delivering social housing, the Trust’s developments are exempt from the Community Infrastructure Levy under Regulation 49 of…

19.10Summary of Applicable Legislation

AreaPrimary Legislation / RegulationHomes England powers and programmesHousing and Regeneration Act 2008, Part 1 (s.19 financial assistance); Social…

Chapter 20 The Ledger of Asks

20Overview

The policy decisions, consents, regulatory changes and legislation requested, ranked by implementation difficulty.

Appendix I Sensitivity Analysis and Risk Register

IOverview

The costing model, the original and adopted pilots, sensitivity to changed assumptions and the risks to delivery.

I.1Purpose

Every model has assumptions.

I.2The Base Case

The financial model rests on the following base case assumptions:

I.3Sensitivity Analysis

Sensitivity Analysis

I.3.1Build Cost

Build cost is the single most important variable in the model.

I.3.2Bond Coupon Rate

The base case coupon is 3% real.

I.3.3Occupancy and Rent Collection

The base case assumes 98% occupancy and 98% rent collection, giving 96% effective income.

I.3.4Construction Cost Inflation vs CPI

The year-36 reissuance model assumes that construction costs track CPI broadly over the long term.

I.3.5Maintenance Cost

The base case allocates 1% of build cost per annum to a maintenance sinking fund, on the construction contract plus fees.

I.3.6Combined Adverse Scenario

The individual sensitivities above are instructive but unrealistic in isolation.

I.4Risk Register

The following register catalogues the principal risks to the scheme, assessed by likelihood (L) and impact (I) on a three-point scale (Low / Medium /…

I.4.1Financial Risks

FR1: Construction cost exceeds budget

I.4.2Regulatory and Legal Risks

RL1: Subsidy control challenge

I.4.3Operational Risks

OR1: Trust management capacity and competence

I.4.4Political and Reputational Risks

PR1: Change of government or policy direction

I.4.5Environmental and Technical Risks

ET1: WikiHouse technology risk / long-term performance

I.5Conclusion

The model is sensitive to build cost.

I.6The Pilot Costing Model

It is not enough to cost the home; the programme has to be costed too.

I.6.1What the Model Adds

Three costs that a bill-of-materials view of the home omits are in the base case.

I.6.2Results

£ per home, October 2026 prices, ex VAT100 homes / 3 sites500 homes / 10 sitesConstruction contract (tendered, incl. prelims, OH&P)173,600173,600Fees,…

I.6.3What Follows

Three conclusions, in order of weight.

I.6.4What the Model Does Not Yet Carry

Landlord repair liability under section 11 beyond the 1% sinking fund; an Awaab’s Law decanting reserve; the administration of statutory rent demands;…

Appendix II Local Economic Circulation

IIOverview

Local procurement, manufacturing, economic multipliers and measurement of spending retained in communities.

II.1The Principle

The Preston Model is the most successful example of community wealth building in the United Kingdom.

II.2Why This Model Is Different: Massive Parallelism

Preston City Council redirected existing procurement.

II.3Low Barrier to Entry

The Manufacturing Guide is the key document.

II.4Always Look Local

The Trust's procurement policy is simple in principle and demanding in practice: for every item of expenditure, the Trust looks local first.

II.4.1Fabrication

Where the reference design is built, its structural components are manufactured by a local fabricator within the development area or as close to it as…

II.4.2Assembly

WikiHouse components are designed for rapid on-site assembly by small teams.

II.4.3Finishing Trades

Once the structural shell is assembled, the finishing trades are entirely conventional: plumbing, electrical, plastering, painting, tiling, kitchen and…

II.4.4Materials

Structural timber is the primary material.

II.4.5Professional Services

Architects, structural engineers, quantity surveyors, project managers, solicitors, accountants, planning consultants.

II.4.6Housing Management

Day-to-day management of the Trust's homes — rent collection, repairs reporting, tenancy management, community engagement — can be delivered by local…

II.4.7Maintenance

The maintenance sinking fund generates a continuous stream of expenditure over the 35-year bond term and beyond.

II.5The Local Multiplier

The New Economics Foundation's Local Multiplier 3 (LM3) methodology measures how many times a pound circulates in the local economy before it leaves.

II.6Creating Local Capacity Where It Does Not Exist

The 'always look local' policy will sometimes find that local capacity does not exist.

II.6.1Fabricator Development

Where no local WikiHouse fabricator exists, the opportunity is visible.

II.6.2Skills and Employment

The Trust recruits assembly workers and tradespeople locally.

II.6.3Social Enterprise and Cooperative Development

The Trust's procurement preference for local suppliers creates market conditions in which social enterprises and cooperatives can form and thrive.

II.7Procurement Framework

The Trust's procurement policy formalises the 'always look local' principle within the constraints of value for money and legal compliance.

II.7.1The Hierarchy

For every procurement decision, the Trust applies the following hierarchy, with 'local' defined as within the local authority area of the development…

II.7.2Evaluation Weighting

Where a competitive procurement exercise is conducted above the Trust's financial thresholds, the evaluation criteria include a local economic impact…

II.7.3Legal Compliance

The Trust is a registered provider and is likely to be a contracting authority within the meaning of the Procurement Act 2023 (Chapter 3.4); whether it…

II.8Measuring and Reporting Local Economic Impact

The Trust publishes annual data on its procurement and local economic impact.

II.9What This Looks Like at Scale

At Proof of Concept — 500 homes across ten sites — the Trust works with a local fabricator or contractor, an assembly team, local tradespeople and…

Appendix III Welfare Savings

IIIOverview

The public cost of housing insecurity, pilot and scale scenarios and the assumptions behind projected savings.

III.1What This Appendix Does

This appendix estimates the welfare expenditure avoided by housing the Trust's target cohort in Trust homes rather than leaving them in the private…

III.2The Current Expenditure

The government currently spends approximately £87.8 billion per year on Universal Credit alone (OBR forecast 2024–25), rising to a forecast £99.0…

III.3How the UC Housing Element Works

How the UC Housing Element Works

III.3.1The Statutory Framework

Universal Credit was introduced by the Welfare Reform Act 2012.

III.3.2The Taper and Work Allowances

UC is a means-tested benefit.

III.3.3What This Means for the Trust's Cohort

The Trust's target cohort has gross household income of £31,500 to £75,000.

III.4Two Rents, Two Cases

The welfare saving from a Trust home is the difference between what the Exchequer pays to support a household in the private rented sector and what it…

III.5The Pilot: 500 Homes at £1,050

At the pilot rent the income floor is about £48,000.

III.6Avoided Indirect Costs

Housing insecurity generates costs across multiple government departments.

III.6.1NHS

Housing insecurity is associated with poorer physical and mental health outcomes.

III.6.2Education

Housing instability disrupts children's education.

III.6.3Criminal Justice

The correlation between housing insecurity and offending is well documented if complex.

III.6.4Local Authority General Fund

Beyond TA costs, local authorities bear costs from housing insecurity through children's services (where housing conditions are a factor in child…

III.7At Scale: The £714 Rent

At scale the levers in Appendix I.6 — par issuance, a tender price that beats the benchmark, and the programme layer spread over thousands of homes —…

III.8What This Does Not Count

The figures above are deliberately conservative.

III.9Conclusion

The government's bond purchase is not expenditure.

III.10Statutory and Regulatory References

InstrumentRelevanceWelfare Reform Act 2012Part 1: introduces Universal Credit. s.11: housing costs element. s.22: work-related requirements.Universal…

Appendix IV Political Consent and the Principle of Reciprocity

IVOverview

The proposal’s account of public support, contribution, fairness and protection of the housing assets.

IV.1The Political Problem

Every government since 1979 has acknowledged the housing crisis.

IV.2The Trapped Middle

The Trust does not target the population currently served by social housing.

IV.3Reciprocity and the Architecture of Public Consent

The Beveridge settlement was built on a contributory principle: you pay in when you are working, you draw out when you are in need.

IV.4Why This Matters for Scale

The history of post-war housing policy is a history of programmes that worked at small scale and failed at large scale because they could not sustain…

IV.5The Design Choices

Every element of the Trust's structure reflects a deliberate decision to build political consent into the architecture of the scheme, not to rely on it…

IV.6The Social Contract Restored

The Fabian tradition has long argued that the welfare state is strongest when it is perceived as a social contract: citizens contribute, and the state…

IV.7Sources

Hills, J. (2007).

Appendix V WikiHouse Skylark — Manufacturing Guide and Microfactory Requirements

VOverview

Workshop space, equipment, skills, cutting files, quality control and the distributed manufacturing approach.

V.1Purpose of This Appendix

The reference design’s price benchmark (Chapter 3.2) and the local economic circulation argument in Appendix II both rest on a factual claim: that…

V.2The Distributed Manufacturing Argument

Most investment in construction innovation to date has followed a centralised model: large offsite manufacturing facilities with setup costs of £15–50…

V.3What a Microfactory Actually Requires

The following sets out the space, equipment, and facility requirements for a WikiHouse Skylark microfactory, as specified in the Manufacturing Guide.

V.3.1Space Requirements

A microfactory can be set up in any dry, secure environment: a large shed, a barn, a warehouse, or existing factory or workshop space.

V.3.2Equipment Requirements

EquipmentSpecificationNotesCNC router (production)Gantry-based; minimum 1220×2440mm (4×8ft) bed; vacuum bed; 9.5–12.5mm router bits; automatic tool…

V.3.3Skills and Personnel

The Manufacturing Guide is written to be followed by a competent workshop operator without specialist training in construction or architecture.

V.4The Skylark Cutting File System

Understanding the Skylark cutting file system is important for assessing the barrier to entry.

V.4.1File Format and Structure

Skylark cutting files are provided in standard DXF format, individually for each block type, already nested onto 2440×1220mm sheets at 1:1 scale.

V.4.2Cutting Parameters

The Manufacturing Guide does not specify a single 'correct' combination of bit size, cutting speed, and number of passes, acknowledging that different…

V.5Materials

Materials

V.5.1Structural Panels

All WikiHouse Skylark components are manufactured from 2440mm × 1220mm × 18mm structurally certified panel product.

V.5.2Insulation

Rolled or soft-fill batt insulation — products such as Supasoft or Rockwool — is used to fill cassette and beam cavities during off-machine assembly.

V.6Production Workflow

The Manufacturing Guide specifies a nine-step production workflow.

V.7Tolerances

Tolerance management is the single most technically demanding aspect of WikiHouse fabrication.

V.8Waste Management

Skylark production generates two categories of timber waste: sawdust and structural offcuts.

V.9Licensing and Open-Source Status

The WikiHouse Manufacturing Guide and Skylark cutting files are published under a Creative Commons ShareAlike licence.

V.10Implications for the Trust's Model

The Manufacturing Guide confirms, from primary technical documentation, the claims made in Chapter 3 and Appendix II of this proposal regarding local…

Appendix VI WikiHouse Switch House — Bill of Materials and Build Cost Analysis

VIOverview

The reference home’s components, materials, labour and the distinction between a building estimate and a funded programme.

VI.1Purpose of This Appendix

The Trust's financial model rests on a tendered construction contract of about £174,000 per home for the reference design and a funded cost of about…

VI.2The Switch House: Design Overview

The Switch House is a three-bedroom, two-storey home of 104m² Gross Internal Area, designed using the WikiHouse Skylark 250 building system.

VI.3Skylark Block Schedule

The Switch House chassis comprises 198 Skylark 250 blocks in six categories, requiring 520 sheets of 18mm structural OSB3 or plywood and approximately…

VI.4Bill of Materials: Cost Summary

The BoM organises costs into six trade sections.

VI.4.1Materials and Manufacturing by Section

SectionKey itemsMaterials cost (ex VAT)Install labour daysFoundations43 helical screw piles @ £120; C24 base frame timber; 12m² timber decking; deck…

VI.4.2Summary Cost Statement

ItemCost (ex VAT)NotesMaterials and manufacturing (self-build estimate)£97,957Includes CNC machining and off-site block assembly at microfactory.

VI.5Relationship to the Trust's Build Cost Assumptions

The Trust's financial model now uses a tendered construction contract of about £174,000 per home and a funded cost of about £211,000 (Appendix I.6).

VI.5.1CNC Machining: £20,800

The single largest labour cost in the BoM is CNC machining of 520 sheets at £40 per sheet.

VI.5.2Off-site Block Assembly: 30 Person/Days at £200/Day = £6,000

The Skylark system is designed for off-site pre-assembly of blocks at the microfactory.

VI.5.3On-site Chassis Assembly: 50 Person/Days at Rate TBC

The BoM records 50 person/days for on-site chassis assembly without specifying a rate, reflecting that assembly does not require specialist…

VI.6The BoM as a Procurement Tool

The Switch House BoM is a procurement document as well as a cost estimate.

VI.7Embodied Carbon

The BoM includes embodied carbon figures for the structural elements where data is available.

VI.8Conclusions

The Switch House BoM confirms four propositions that are central to the Trust's model:

Appendix VII Lender Capacity Constraints

VIIOverview

Mortgage funding, bank capital requirements and the limits of expanding housing access through lending.

VII.1Purpose

This appendix justifies a statement that appears throughout the main proposal: “The financial system lacks sufficient capacity to expand mortgage…

VII.2How Bank Lending Actually Works

A common misconception is that banks lend out money deposited by savers.

VII.3The Three Regulatory Constraints

The Three Regulatory Constraints

VII.3.1Capital Adequacy Ratio (CAR)

For every loan a bank creates, the bank must hold a minimum quantity of its own capital — equity, retained earnings, and certain qualifying instruments…

VII.3.2Risk-Weighting (Basel 3.1)

Not all lending consumes capital equally.

VII.3.3The Leverage Ratio: The Hard Cap

Risk-weighting can be gamed.

VII.4The Current Position: A Saturated System

As at Q3 2025, the outstanding value of all residential mortgage loans in the UK stood at £1,733.7 billion (Bank of England/FCA MLAR statistics, Q3 2025).

VII.5The Scale Problem

England needs approximately 300,000 new homes per year to meet demand and begin addressing the accumulated backlog (MHCLG’s stated target: 1.5 million…

VII.6Capital Rationing and Who Gets Served

When capital is scarce, banks do not ration lending randomly.

VII.7Why Relaxing the Constraints Is Not an Option

An obvious response is: loosen the rules.

VII.8How the Trust Bypasses the Constraint

The Trust’s funding model does not touch the banking system’s balance sheet.

VII.9The Cost of Doing Nothing

If the mortgage market cannot scale to meet housing need, and the prudential constraints on lending cannot be relaxed without creating systemic risk,…

VII.10Statutory and Regulatory References

Bank of England (2014). ‘Money Creation in the Modern Economy.’ Quarterly Bulletin 2014 Q1, pp.14–27.

Appendix VIII Construction Sector and Skills Constraints

VIIIOverview

Workforce and training constraints, production methods, quality and the case for manufactured construction.

VIII.1Purpose

This appendix justifies the statement appearing throughout the main proposal: “traditional construction methods are too slow and expensive to deliver…

VIII.2The Productivity Crisis

Construction is one of the only sectors in the UK economy where labour productivity has effectively stagnated over a generation.

VIII.3The Skills Shortage

The Skills Shortage

VIII.3.1The Scale of the Shortfall

The Construction Industry Training Board (CITB), the statutory body responsible for workforce planning in the sector, publishes annual labour market…

VIII.3.2The Government Response: Insufficient by an Order of Magnitude

In March 2025, the government announced plans to recruit and train up to 60,000 more specialist construction workers by 2029.

VIII.3.3An Ageing Workforce

The shortage is structural, not cyclical.

VIII.3.4Post-Brexit Labour Market Contraction

The UK construction sector was historically reliant on skilled EU labour, particularly from Poland, Romania, and the Baltic states.

VIII.3.5Recruitment Failure

The sector has a persistent and well-documented recruitment problem.

VIII.4The Apprenticeship Pipeline Is Broken

The conventional policy response to a skills shortage is to train more workers.

VIII.5Cost Inflation Driven by Scarcity

A skills shortage does not merely slow construction.

VIII.6Industry Fragility: Insolvency and Supply Chain Risk

The UK construction sector has the highest business failure rate of any industry in the economy.

VIII.7Quality and Defects

The quality of traditionally built new homes is a matter of public record and public dissatisfaction.

VIII.8Weather Dependency and Programme Risk

Traditional construction is critically dependent on weather conditions.

VIII.9“Modernise or Die”: The Farmer Review

The systemic failure of the traditional construction model was officially recognised in the government-commissioned 2016 Farmer Review of the UK…

VIII.10The Training Timeline Problem

Even if the political will existed to solve the skills shortage through conventional training, the timescale is prohibitive.

VIII.11The Cumulative Effect

Each problem described above is individually significant.

VIII.12The Construction Method Is Not a Detail

Housing policy debate in England focuses overwhelmingly on land, planning, and finance.

VIII.13References

BCIS (2025).

Appendix IX Questions Requiring Legal Opinion Before Implementation

IXOverview

The legal conclusions requiring commissioned advice before the programme proceeds.

IX.1Purpose

This document has been prepared without commissioned legal advice.

IX.3Questions of Fact the Trust Must Answer Itself

Three further questions are not legal and no counsel can answer them.

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