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Maidstone Borough Council Placement Policy


Final Decision-Maker

Communities, Housing & Environment Committee

Lead Head of Service

John Littlemore

Lead Officer and Report Author

Hannah Gaston

Stuart Clifton



Wards affected



Executive Summary

This report asks the Communities, Housing and Environment Committee to endorse our Placement Policy (appendix 1).


In order for MBC to adhere to relevant case law and good practice the Housing Advice service has developed the attached policy which gives a framework and structure to the allocation of both temporary accommodation and Private Rented Sector Offers (PRSO) to homeless applicants who have approached for housing assistance.  The policy will enable MBC to work in a structured and transparent manner when allocating properties which at times will sit outside of our district boundaries.



Purpose of Report





This report makes the following recommendations to this Committee:

1.   That the attached Placement Policy is endorsed.

2.   That the policy is reviewed after 12 months to monitor the impact and ensure no unintended detriment is being caused to any specific groups of people – as set out in our Equalities Impact Assessment. 







CHE Committee

5th January 2021

Maidstone Borough Council Placement Policy








Impact on Corporate Priorities

The four Strategic Plan objectives are:


·         Embracing Growth and Enabling Infrastructure

·         Safe, Clean and Green

·         Homes and Communities

·         A Thriving Place


·         Accepting the recommendations will materially improve the Council’s ability to achieve our priority in relation to Homes and Communities.  We set out the reasons other choices will be less effective in section 2.

John Littlemore

Head of Service

Cross Cutting Objectives

The four cross-cutting objectives are:


·         Heritage is Respected

·         Health Inequalities are Addressed and Reduced

·         Deprivation and Social Mobility is Improved

·         Biodiversity and Environmental Sustainability is respected


The report recommendations support the achievement of the Deprivation and Social Mobility cross cutting objectives by enabling the Council to resettle homeless households across the country into accommodation which is affordable and suitable.


John Littlemore

Head of Service

Risk Management

Already covered in the risk section.

John Littlemore

Head of Service


The proposals set out in the recommendation are all within already approved budgetary headings and so need for new funding for implementation.


Mark Green

Director of Finance and Business Improvement


We will deliver the recommendations with our current staffing.


John Littlemore

Head of Service


·         Accepting the recommendations will fulfil the Council’s duties under The Housing Act 1996 and the Homelessness Reduction Act 2017.  Failure to accept the recommendations without agreeing suitable alternatives may place the Council in breach of The Homelessness Code of Guidance.

·         The Council is not legally obliged to have a placement policy, but it is recommended by The Homelessness Code of Guidance, provides transparency for Officers and the public and lowers the risk of legal challenges of the Council’s placement decisions.


Mid Kent Legal Team Leader (Contentious)

Privacy and Data Protection

Accepting the recommendations will not increase the volume of data held by the Council.  We will hold that data in line with our retention schedules.

Policy and Information Team


We recognise the recommendations may have varying impacts on different communities within Maidstone.  Therefore, we have completed a separate equalities impact assessment and we will review the policy after 12 months to monitor the impact.

Equalities and Corporate Policy Officer

Public Health



We recognise that the recommendations may have varying impacts on the health of the population or individuals within Maidstone.


Public Health Officer

Crime and Disorder

The recommendation will have no impact on Crime and Disorder. The Community Protection Team have been consulted and mitigation has been proposed.

Head of Housing & Community Services


On accepting the recommendations, the Council will not need to follow a procurement exercise.

Head of Service & Section 151 Officer











2.1   The demand for both temporary accommodation (TA) and settled accommodation is growing across our district with the number of applicants who are approaching the Council for resettlement support growing each year. In the preceding four years we have had an incremental increase, as set out below:


·           2017/18 – 654 homeless approaches

       2018/19 – 1214

       2019/20 – 1327

       2020/21 – 856 year to date (to 16/12/20)


2.2   This increase in homelessness approaches has naturally led to a greater demand on longer term accommodation including both affordable housing through the Housing Register and access to the private rented sector through our Homefinder Scheme. As such, the pool of decent affordable units within Maidstone is shrinking, as new build affordable housing cannot keep pace with demand. We are finding it considerably more difficult to place the growing number of households within our district boundaries.


2.3   Alongside the increase in our own local demand, we are also competing for both TA and longer-term accommodation with other districts and boroughs including unitary London Authorities, who have a far more generous budget and funding streams than MBC. We are aware that one London authority has placed 189 households from their area into Maidstone alone.


2.4   These pressures have led us to consider the manner in which we allocate our resources based on household composition; community contribution including work and volunteering; and social and welfare needs. In the attached, MBC Placement Policy, we have set out how we will seek to work with households based on their priorities, presenting needs and affordability in order to offer the most appropriate accommodation for both TA and through the Private Rented Sector as a longer-term housing solution.


2.5   The Placement Policy will ensure we comply with the relevant case law, including the Supreme Court judgment in the case of Nzolameso v City of Westminster [2015] UKSC 22 and the Court of Appeal decisions in the cases of Alibkheit v London Borough of Brent and Adam v City of Westminster [2018] EWCA Civ 2742, which set out that Local Housing Authorities should adopt a structured and fair process, which determines how applicants will be prioritised for accommodation in our district and beyond.


2.6   Whilst the starting point is to offer accommodation in our own area, this policy acknowledges that there are circumstances when this cannot be achieved. At times this will mean accommodation being offered outside of our district if we deem it to be suitable and meets the requirements as set out by Part 7 of the Housing Act 1996, and the Homelessness Reduction Act 2017; statutory guidance on suitability; and the Homelessness Code of Guidance. In offering the accommodation we will consider a number of factors to ensure suitability and will be transparent with the applicant about the rationale.


2.7   If the applicant refuses the offer of accommodation and cannot provide further evidence that it would be unsuitable we will discharge our duty and no longer be under a duty to secure accommodation for the applicant. An ongoing duty to provide advice and assistance continues and this may include access to the Housing Register and assistance with obtaining private rented accommodation.


2.8   The decision on ending our duty to secure accommodation will not be taken lightly and the policy speaks to our aspiration of working in a supportive and transparent manner.


2.9   In order to offer some context about our placements and how frequently this occurs, over the preceding two years we have placed 147 households in to longer term private rented accommodation via our Homefinder Service, of those, 30 have been outside of our district.


2.10 The demographics of that 30 is as follows:


·                1 beds – 11           36%

·                2 beds – 13           43%

·                3 beds – 1             3%

·                4 beds – 5             17%


2.11 One area of accommodation we struggle to procure within the district boundary is property big enough for larger families that is both affordable and suitable. Four bedroomed social housing stock is very limited and larger properties in the private rented sector in Maidstone are often unaffordable. As the figures above demonstrate, nearly a fifth of the PRS outside of the borough is for those households, which is a disproportionate number given that four bed need only makes up five percent of Housing Register applicants.


2.12 In our Homefinder Officers’ experience, some clients express an anxiety about being offered accommodation beyond our boundaries but with reassurance and support these anxieties can be managed to ensure successful resettlement.





3.1     The Committee could choose to do nothing but this is not recommended because if we continue to operate without an adopted Placement Policy, this could leave MBC open to legal challenge and in a precarious position when seeking to end our duties by making an offer of suitable accommodation which sits outside our district boundaries. Households would be in temporary accommodation for longer than necessary which would lead to a negative financial cost implication.


3.2     CHE Committee endorse the MBC Placement Policy. This is implemented with immediate effect – ensuring those households in TA can be offered appropriate accommodation outside of the district in accordance with an adopted policy that reflects the relevant case law and good practice. This may mean households we have an open duty to, could be offered accommodation beyond our district boundaries – but this will be undertaken in a transparent and consultative manner with the applicant.






4.1     Our preferred option is for the CHE Committee to endorse the MBC Placement Policy with immediate effect, this will enable the Housing Advice service to work within a framework with households to ensure good quality affordable housing options are offered to applicants.


4.2     The Placement Policy will give the housing service team a structure in which to work and also provides transparency to our customers on how allocations will take effect. MBC will also be working within the spirit of good practice and relevant case law.


4.3     The secondary outcome of this we hope would support a reduction in our TA budget moving forward as we can offer more households (currently residing in TA) offers of private rented accommodation which means their housing journey will come to an end quicker that previously.



5.       RISK


5.1    The risk of not adopting a policy means that the Council is not adhering to relevant case law and good practice, which could leave the Council open to legal challenge and would be looked upon unfavourably by the Court.


5.2    The policy also enables us to work closely with applicants in a transparent and fair way – this ensures an equitable process for all – instead of an approach that is perceived to be subjective by an aggrieved applicant.



Only a light touch consultation with our specialist Homelessness Advisor at the Ministry of Housing Communities and Local Government – i.e. they have requested to see our policy indicating we need to have one.





7.1     If the policy is endorsed the Housing Advice Manager will inform the Housing Advice Service to ensure the team are properly trained and understanding of the new processes.


7.2     The policy will be uploaded on to our website so the general public can review and have access, ensuring transparency.


7.3     Finally, we will monitor who the policy is used for over the coming twelve months – and review in line with our Equalities Impact Assessment – if a particular cohort or group are being unfairly discriminated by these processes.








·         Appendix 1: MBC Placement Policy









































Appendix 1


Maidstone Borough Council Placement Policy

January 2021 – January 2022



This document sets out Maidstone Council’s policy for the placement of households in temporary accommodation and private rented accommodation, both inside and outside of the Maidstone Borough. It covers both interim placements made under section 188 Housing Act 1996 (“HA96”), while homelessness enquires are undertaken, longer term temporary accommodation placements for households accepted as homeless under section 193 HA96 and a private rented sector offer defined by section 193(7AC) with a view to bringing the section 189B(2) duty, or section 193(2) duty to an end.


The policy complies with:


·         The Housing Act 1996, as amended by the Homelessness Act 2002

·         The Localism Act 2011

·         Equality Act 2010

·         Homelessness (Suitability of Accommodation)(England) Orders 1996, 2003 & 2012.

·         Supplementary Guidance on the Homelessness changes in the Localism Act 2011 & the Homelessness (Suitability of Accommodation)(England) Order 2012

·         The Homelessness Code of Guidance

·         The Homelessness and Rough Sleeper Strategy 2019-2024

·         The Allocation Scheme

·         Children Act 2004 (in particular section 11)

·         Relevant decisions by the Courts including the Supreme Court judgment in the case of Nzolameso v City of Westminster [2015] UKSC 22 and the Court of Appeal decisions in Alibkheit v London Borough of Brent and Adam v City of Westminster [2018] EWCA Civ 2742.


1.1        The policy takes into account the statutory requirements on local authorities in respect of suitability of accommodation as per Section 206 Housing Act 1996 (HA96), including Suitability Orders, Supplementary Guidance on Homelessness changes in the Localism Act 2011 and on the Homelessness (Suitability of Accommodation (England) Order 2012 , the Homelessness Code of Guidance 2018, the Children Act 2004 s.11 which places duties on a range of organisations and individuals to ensure their functions, and any services that they contract out to others, are discharged having regard to the need to safeguard and promote the welfare of children.


1.2        As per Section 208 Housing Act 1996, and paragraph 17.50 of the Homelessness Code of Guidance, so far as reasonably practicable, the Council seeks to accommodate homeless households as close as possible to where an applicant was previously living and always considers the suitability of the accommodation, taking into account the circumstances of the individual household. However, due to an acute shortage of affordable housing locally, and rising rental costs, an increasing number of households are likely to be placed outside the borough, as it will not be reasonably practicable to provide accommodation within Maidstone. The application of housing benefit caps, Local Housing Allowance rates within the borough, welfare reform and universal credit, together with restrictions upon overall benefit entitlement, has further restricted the number of properties that will be affordable to homeless households in Maidstone, and particularly larger families.


1.3        When determining whether it is reasonably practicable to secure accommodation in Maidstone, as opposed to simply what is reasonable, the cost of the accommodation is a relevant and proper consideration. Matters to be taken into account here include information provided by the applicant, together with paragraph 17.45 of the Homelessness Code of Guidance. The reality however, is that the demand for housing greatly exceeds supply in respect to securing affordable Private Rented Sector Offers (PRSO) accommodation and  all forms of temporary accommodation within our borough boundaries.


1.4        The scale of demand and the limitations on resources are such that the Council and its partners cannot build enough affordable accommodation for households on lower incomes to meet all housing need. Even if resources were available, there is a limit to capacity given that the opportunities for large scale new development in Maidstone are constrained by land availability and costs.


1.5        The Local Housing Allowance is used to work out how much Housing Benefit a tenant will receive to pay their rent. LHA rates depend on who lives in the household, and the area they are making their claim in. These areas are called Broad Rental Market Areas (BRMA).


1.6        The local authority area of Maidstone is divided into two Broad Rental Market Areas, which are used to calculate LHA rates in Maidstone. Maidstone BRMA and Medway & Swale BRMA. There are costs savings to be made by utilising accommodation in areas outside of the two BRMA’s in Maidstone. Appendix 1 provides a link to the Valuation Officer Agency website where the LHA rates for each borough can be searched.


1.7        The Council is making efforts to ensure that its temporary accommodation portfolio reflects the most common locations for applicants presenting as homeless in our district. However, inevitably we cannot always meet the requested location that an applicant presenting as homeless may wish to be temporarily housed in.


1.8        The policy therefore details how applicants will be prioritised for housing inside the Maidstone borough and out of borough.



2.0         PRSO and Temporary Accommodation Lettings


2.1        Due to the shortage of suitable accommodation in Maidstone, homeless applicants who are housed under the Council’s interim duty to accommodate pursuant to section 188 HA96 may initially be placed in emergency accommodation, including bed and breakfast and short-term self-contained accommodation, such as annexes, or nightly-paid accommodation while enquires are carried out. This accommodation may be outside of the borough. If the Council decides the Section 193(2) main housing duty is owed , they will be moved to longer-term temporary accommodation or made a PRSO as soon as a suitable property becomes available.


2.2        Wherever possible and in compliance with the regulations, the Council will avoid placing families with dependent children, pregnant women and young people aged 16/17, in bed and breakfast accommodation. Where no other suitable accommodation exists and such placements are necessary, the Council will move these households to more suitable self-contained accommodation within six weeks.


2.3        Where the Council decides that applicants housed under section 188 HA96 are not owed the main homelessness duty, they will be asked to leave after a reasonable period, usually not less than fourteen days from receipt of a homelessness decision letter.


2.4        Applicants will be given one offer of suitable accommodation. This may be under an interim duty while enquiries are being carried out, or longer-term temporary accommodation where the main housing duty has been accepted, or a PRSO.


·           Offers of temporary accommodation will be made verbally over the phone by the Accommodation Team and followed up in writing thereafter.


·           If a PRSO is being offered the Housing Advice Service will discuss the potential offer with the applicant in a supportive manner, explaining why this decision has been made and follow this up in writing. The applicant will be advised to accept the offer made, with both the Officer and the offer letter explaining the consequences of refusal and any right of review that they have of the suitability of the offer of accommodation. There is no obligation upon the Council to enable applicants to view the accommodation prior to acceptance but in terms of a PRSO we would endeavour to enable a viewing. In making the offer, the household’s individual circumstances will be considered, taking into account the factors set out in section 3 of this policy and the Council’s criteria on in/out of borough placements detailed in section 4.


2.5        If an applicant rejects an offer, they will be asked to provide their reasons for refusal. This applies to new applicants to whom the Council has an interim duty to accommodate under section 188 HA96, as well as those being transferred from existing Temporary Accommodation or those in TA who are required to move by the Council whom the Council has accepted a rehousing duty towards under Section 193 HA96. The Council will consider the reasons given and undertake further enquires as necessary. If the Council accepts the reasons for refusal and agrees the offer is unsuitable, the offer will be withdrawn and a further offer will be made.


2.6        Where applicants refuse suitable interim/temporary accommodation (which may include out of borough placements) and the Council does not accept their reasons for refusal and considers that the offer is suitable, applicants will not be offered further accommodation and will be required to make their own arrangements. The offer of interim/temporary accommodation will remain open for a period of 24 hours. There is no right of appeal against the suitability of accommodation offered to applicants under section 188 HA96 (although they can apply for Judicial Review through the courts).


2.7        In cases where the applicant still refuses a suitable offer of accommodation, after having been informed that the Council has not accepted their reasons for refusal, the interim homelessness duty will be discharged. If the applicant is resident in interim accommodation, they will usually be asked to vacate the property within 14 days and advised that no further assistance will be provided.


2.8    If they are already in longer-term temporary accommodation, the main housing duty will be discharged, and the applicant will be served with the appropriate Notice to Quit this accommodation. For applicants where the Council has accepted a rehousing duty under section 193 HA96, (s.193 duty) there is a right to request a review of the suitability decision, pursuant to section 202 HA96.


2.9    Where applicants, for whom the Council has accepted a s.193 duty refuse a suitable offer and submit a review request, they will only continue to be accommodated during the review period in exceptional circumstances. The Council will apply the principles laid down in the judgment in R (Mohammed) v Camden LBC [1997] 30 HLR 315 when reaching a decision on providing discretion to accommodate an applicant pending a review. Each case will be considered on an individual basis, taking into account the overall merits of the review request, any new information or evidence that may affect the original decision, the personal circumstances of the applicant and the potential impact of the loss of accommodation.


3.0        Suitability of accommodation


3.1        In offering interim, temporary or private sector accommodation, the Council will consider the suitability of the offer, taking into account the following factors:


3.2        Accommodation available in the borough

If suitable accommodation is available in the local authority area, the Council will seek to house applicants in Maidstone, allowing them to maintain any established links with services and social/support networks. However, when there is a lack of suitable accommodation or there are higher priority households awaiting accommodation in the borough, out of borough placements will be used to meet the Council’s housing duty (see section 4 on priority for local accommodation below). Given the shortage of accommodation locally, bed and breakfast in/outside of the borough may be considered suitable for short-term interim placements.


The Council may also keep aside local vacant units in anticipation of applicants presenting who meet the criteria for a local placement. This has been confirmed as a reasonable practice in the Court of Appeal decisions in Alibkheit v Brent LBC and Adam v Westminster.


3.3        Affordability

‘Affordability’ as defined in this policy means: “the household must have its equivalent level of income support or income-based Jobseeker’s Allowance (whether claimed or not) available to spend on reasonable living costs after accommodation costs have been deducted from the household’s income”. Due regard will be given to s.17.45 of the Code of Guidance 2018 when assessing affordability.


3.4        Size and location of the property and availability of support networks in the area

Accommodation must provide adequate space and room standards for the household in light of the relevant needs, requirements and circumstances of the household (e.g. health or mobility issues and free from any Category 1 Hazards under the Housing Health Safety Rating System).


The Council will consider whether the applicant can afford to pay for their accommodation without being deprived of basic essentials such as food, clothing, heating, transport costs and all other reasonable expenditure. We will therefore take into account the rent that the household can afford as well as any additional costs, such as travel costs, resulting from the location of the accommodation.


In deciding on the fitness of the property, consideration would be given to the length of time needed to complete any necessary repairs and whether it is reasonable to complete these while the property is occupied. The quality of the decoration/furniture, the layout/type of accommodation, provision of parking and lack of access to a garden are unlikely to be acceptable reasons for a refusal.


3.5        Health factors

The Council will consider health factors, such as ability to get up the stairs, care and support provided by other statutory agencies or the need to access any specialist medical services that are only available in Maidstone. If the applicant or a member of the resident household is citing medical grounds that were not identified during the initial assessment, the applicant must submit medical evidence within 48 hours. The key test in determining the impact of medical issues is whether the condition itself makes the housing offered unsuitable. Problems such as depression, asthma, diabetes or back pain would not normally make a property unsuitable, as the problems would persist in any accommodation.


3.6        Education

Attendance at local schools will not be considered a reason to refuse accommodation, though some priority will be given to special educational needs and students who are close to taking public examinations in determining priority for in-borough placements (see Section 4).



3.7        Employment

The Council will consider the need of applicants who are in paid employment to reach their normal workplace from the accommodation that is secured (see Section 4)


3.8        Proximity to schools and services

The Council will consider the proximity to schools, public transport, primary care services, and local services in the area in which the accommodation is located


3.9        Pet ownership

If a household arrive into temporary accommodation with a pet, the first offer of accommodation can be refused without penalty if it wasn’t suitable for pet ownership or they were not able to take their pet with them. The Housing Advice Officer should be aware of this requirement before making an offer – to try and seek the most suitable placement for the household.


3.10     Any special circumstance

The Council will consider any other reasons for refusal put forward by the applicant and come to an overall view about whether the offer is suitable.



4.0    Criteria for prioritising placements inside and outside of the Maidstone borough


4.1     It is the Council’s preferred position to house applicants within the Maidstone Borough. The Council acknowledges that in the current housing market it will be necessary to make decisions about the suitability of out of area placements for individual households and balance these against the type and location of temporary accommodation and private rented accommodation that can be offered. In some cases, housing outside of the borough might be more sustainable for the household in the long-term, with lower rents allowing them to better meet their subsistence and household costs and avoid rent arrears.


4.2     In placing households in temporary accommodation and private rented accommodation, there will be a general presumption that placements outside of Maidstone may be used to discharge housing duties where the accommodation is suitable and where an affordable accommodation solution is not available locally.


4.3     Our preference for resettlement will follow a stepped approached, we will seek accommodation within our district, then to the wider County of Kent and finally we may consider placements outside of Kent across the whole country. All of these options will be fully considered using the prioritisation listed below. However, we may at times withhold available accommodation in the district or the wider Kent County if we feel other households would be more in need as set out in Alibkheit v London Borough of Brent and Adam v City of Westminster. Each application will be assessed according to the household’s presenting needs.





Placements within the Maidstone borough


4.4     Priority for in-borough accommodation will be given to certain households whose circumstances indicate that they would best be housed locally. These include but not limited to:


·         Applicants with a severe and enduring health condition requiring intensive and specialist medical treatment that is only available in Maidstone.

·         Applicants who are in receipt of a significant package and range of health care options that cannot be easily transferred.

·         Applicants with a severe and enduring mental health problem who are receiving psychiatric treatment and aftercare provided by community mental health services and have an established support network where a transfer of care would severely impact on their wellbeing.

·         Households with children registered on the Child Protection register in Maidstone, or families who have high social needs who are linked into local health services and where it is confirmed that a transfer to another area would impact on their welfare.

·         Households containing a child with special educational needs who is receiving education or educational support in Maidstone, where change would be detrimental to their well-being.

·         Households containing one or more children in secondary school in their final year of Key Stage 4 (generally Year 11) with exams to be taken within the next six months

·         Applicants who have a longstanding arrangement to provide care and support to another family member in Maidstone who is not part of the resident household and would be likely to require statutory health and social support if the care ceased.

·         Any other special circumstance will also be taken into account



Priority for placements in the county of Kent will be given to:


4.5     Applicants who have been continuously employed in Kent for a period of six months, and for 24 hours or more per week. Women who are on maternity leave from employment and meet the above criteria would also be prioritised for placements in Kent.


4.6     Applicants who have as part of their household, a child or children who are enrolled in public examination courses in Maidstone, with exams to be taken within the next six months. Wherever practicable the Council will seek to place such households within 60 minutes car travelling distance of their school or college.


4.7     Wherever practicable, any applicant who works for more than 24 hours per week and has been employed continuously for more than six months will not be placed more than 90 minutes travelling distance by public transport, from their place of employment.


4.8     Applicants who meet none of the above criteria may be offered properties out of Kent when no suitable property is available.


4.9     Applicants who are victims of domestic violence would be placed outside of Maidstone in an area where the risk of violence or abuse does not exist, having given consideration to all other factors within this policy.


4.10   Applicants who are at risk of violence being perpetrated against them will be placed outside of Maidstone in an area where the risk of violence does not exist, having given consideration to all other factors within this policy.


4.11   Applicants who indicate a desire to be housed in a particular area outside of Maidstone will be housed in those area(s) so far as reasonably practicable.


4.12   Any other special circumstance will be taken into account.


Notification arrangements when households are placed outside of Maidstone


4.13   The Council, when discharging a homeless duty, will aim to ensure that information concerning details of placements in temporary accommodation and private rented accommodation outside Maidstone is shared as far as possible in a fair and timely manner with the relevant Local Housing Authority in areas where families are moving to.


4.14   Notification arrangements – The Council will notify the receiving LHA of any placement (as far as this is possible). The receiving LHA should also notify MBC as to any action they may have taken against a landlord/agent.


4.15     Pay a Fair Rent – The Council will, as far as is practical, ensure that the rent paid is in accordance with the prevailing local housing allowance rent levels and is not at a level that is likely to encourage inflation of rent levels.

4.16     Vulnerable families – So far as is practicable, if placing vulnerable families outside of Maidstone the Council will ensure that such families will continue to receive appropriate support.


This Temporary Accommodation and Private Rented Sector Placement Policy has been Adopted by the Communities, Housing & Environment Committee on date TBC


















Appendix 1 – LHA Rates