Affordable-housing contribution records in the five national datasets examined.
P—47 · public-interest evidence submission · 22 September 2026
Where Have All
the Houses Gone?
Section 106 Affordable Housing: A Request for Reconciliation and Coordinated Investigation
Where have all the houses gone?
Some may have been built. Some may have been lawfully changed. Some may have moved elsewhere or become financial contributions. The public record should allow everyone to see which is which.
Start with the covering letter ↗The title respectfully alludes to Pete Seeger’s Where Have All the Flowers Gone?. The song’s lyrics are not reproduced or rewritten here. The words on this page are an original public-interest framing for the housing evidence.
Look for yourself
Do not be ruled
by fear.
When a public record leaves a reasonable question unanswered, ask it clearly and provide the evidence.
Some authorities possess powers to act on their own initiative; others require a complaint, referral or evidence meeting a particular threshold. No organisation can examine information it has never received.
Ask for acknowledgement, a reference number, a named responsible team, preservation of the evidence, a documented handover where responsibility changes, and a written account of the outcome.
The public-interest question
What was promised?
What happened next?
Can every affordable home originally secured through a Section 106 planning obligation be accounted for through an identifiable and lawful chain of delivery, variation, substitution, financial contribution or discharge?
The investigation preserves the first executed affordable-housing requirement as an Original Promise Baseline, then records later events separately. A later change is not presumed improper. The method asks what changed, why, under which power, who authorised it and where the housing, money or other public benefit ultimately went.
An unmatched or unreconciled record does not prove that a home was never delivered, that an obligation was breached or that anybody acted unlawfully. It shows that the downloaded national data alone do not complete the evidential chain. Legitimate delivery, phasing, variation, tenure change, off-site provision, payment, incomplete publication and data-quality problems must all remain possible until the underlying records are examined.
Evidence at a glance
A priority for inquiry.
Not a verdict.
A reproducible review of five national datasets identifies a large historical baseline and a smaller group worth tracing first.
The historical quantity represented by those contribution records.
Records matched by an authority-scoped contribution key to a national transaction record containing a unit quantity.
Unit-bearing records representing 1,037 original units; six have a matching unit-bearing transaction in the downloaded national extract.
Original promise → current outcome
Follow every lawful route.
Keep every boundary.
Physical housing, changed tenure, an off-site replacement, a financial contribution, an unfinished development and an incomplete record are different outcomes. They should not be collapsed into one accusation—or one reassuring total.
- 01
Preserve the original Section 106 affordable-housing obligation as the historical baseline.
- 02
Identify every later variation, modification, discharge, substitution or commuted payment.
- 03
Verify the legal instrument, decision, statutory power and delegated authority behind each material change.
- 04
Trace homes delivered on site, in phases or at another site against the enforceable obligation.
- 05
Trace money replacing housing through receipt, allocation, expenditure and any repayment.
- 06
Reconcile national statistics with planning, property, provider and local financial records.
- 07
Correct data or classification problems before treating a case as genuinely unreconciled.
- 08
Refer an individual case for specialist audit, regulatory or investigative examination only when its evidence reaches the relevant threshold.
Coordinated responsibility
No single authority holds
the whole chain.
No single authority holds the complete evidential chain or can complete this reconciliation alone. Each body must act independently within its lawful powers while cooperating with the bodies holding documents, data, money records, regulatory authority or investigative capability.
Ministry of Housing, Communities and Local Government
Convene the national planning, housing and local-government response; identify ownership where responsibilities cross systems.
Digital Land + MHCLG Planning Statistics
Examine agreement, contribution and transaction publication, identifiers, superseded records and national reconciliation.
MHCLG Housing Statistics
Examine Affordable Housing Supply and Local Authority Housing Statistics methodology and consistency.
Office for Statistics Regulation
Consider concerns about the quality, transparency and public use of official statistics. OSR may also act without a complaint.
Public Sector Fraud Authority
Support public bodies where evidence indicates public-sector fraud or error risk; a statistical gap alone is not such a finding.
Planning authority + Monitoring Officer
Produce agreements, variations, registers, monitoring and enforcement records; test legality, governance and delegated authority.
Section 151 Officer + appointed external auditor
Trace commuted sums, financial governance, expenditure and the relevant audit trail.
Regulator of Social Housing and/or Homes England
Participate only where a named registered provider, regulatory standard, funding programme or Homes England record is implicated.
Copying relevant bodies does not give them new powers or allow one organisation to authorise another. It creates a visible, accountable starting point. Each recipient must identify its own lawful role, coordinate where powers and records meet, and document the handover where responsibility changes.
Core national copies
Address the system.
Copy the evidence holders.
Use the MHCLG correspondence route as the primary national route, then copy the bodies responsible for the relevant national datasets and oversight. For an individual development, research the authority, provider, funding and audit chain first and include only the case-specific bodies with jurisdiction.
Open the MHCLG contact route ↗Before copying an individual case
Research the route.
Do not broadcast suspicion.
Include the relevant council’s Head or Director of Planning or Section 106 monitoring team; its Monitoring Officer for legality, governance and delegation; its Section 151 Officer for public money; and its appointed external auditor where the financial trail is material.
Include the Regulator of Social Housing only where a named registered provider or regulatory standard is implicated, and Homes England only where its funding, programme or records are implicated. Ombudsmen, the National Audit Office, Report Fraud, police or the Serious Fraud Office belong to later or case-specific routes when their jurisdiction and evidence threshold are actually met.
A statistical gap is not a criminal allegation. Public copying should improve preservation, coordination and accountability—not stigmatise people or organisations before facts are established.
A response people can follow
No silent handover.
No disappearing question.
- 01
Acknowledge receipt and provide a reference number.
- 02
Name the team responsible for each part of the question.
- 03
Preserve the evidence held by each organisation.
- 04
Record every referral, transfer and handover instead of allowing the trail to end.
- 05
State what can be decided, what remains uncertain and what further evidence is needed.
- 06
Ask for staff, expertise or help when the work is larger than one team can safely complete.
- 07
Publish the reconciliation outcome, including lawful delivery and innocent explanations as clearly as any unresolved discrepancy.
Asking for help with a complex public system is responsible administration, not failure. Resolution requires enough people, expertise and time to establish what was promised, what changed, what was authorised, what was delivered and where the public resource went.
Publication documents
Begin simply.
Then inspect the record.
Both supplied PDF records are preserved. The short letter provides the coordinated route; the combined pack carries that letter together with the investigation, evidence framing, routing and supporting analysis.
Start here · 4 pages · PDF · 123 KBCoordinated Cross-Agency Covering LetterSHA-256 · f94148f8adb79b215b54a2b4369070d6d8efafe775a0e779a37e9d8dd7976104↗Full record · 23 pages · PDF · 260 KBSection 106 Cross-Agency Combined InvestigationSHA-256 · 304a653f6ede7382675fbdcfeebfd443c0928758e8b6c93ee71683a1eb238bc4↗