[1] The Commission could be ordered by the Secretary of State to undertake "structural reviews" in specified areas and recommend the creation of unitary authorities in the two-tier shire counties of England.

The Commission, chaired by John Banham, conducted a review of all the non-metropolitan counties of England from 1993 to 1994, making various recommendations on their future.

Combined with a second wave of reviews in 1995, under the chairmanship of David Cooksey, the Commission's proposals led to the creation of unitary authorities covering many urban areas of England, including cities like Bristol, Kingston upon Hull, Leicester, Derby, Nottingham, Stoke-on-Trent and Plymouth.

Whilst Heseltine had expressed a wish for most of the country to become unitary authorities, Howard issued revised guidance on the basis that the "two-tier structure may be appropriate in some areas", and that the costs of reorganisation might be too much for the recession-hit UK economy to take.

The process was originally supposed to take some years, with the shire counties being considered in five waves, or "tranches", and it was hoped that the reforms would come into effect from 1994 to 1998.

[11] The first tranche, covering Avon, Cleveland, Derbyshire, County Durham, Gloucestershire, the Isle of Wight, Humberside, Lincolnshire, North Yorkshire and Somerset was nearly done by the end of 1993.

In both Derbyshire and Durham, unitary authorities would be created covering the large urban areas, but the rest of the county would remain two-tier in structure.

Gummer sped-up the work plan and directed that all remaining reviews should start in December and be complete by the end of 1994.

The revised guidance included wording as follows:[21][22] In some areas the commission may wish to recommend a continuation of the existing two-tier structure.

But the government expects that to be the exception, and that the result will be a substantial increase in the number of unitary authorities in both urban and rural areas.Lancashire and Derbyshire County Councils, fearing their abolition under the new guidance, took a case to the High Court, seeking a judicial review that it was illegal.

On 28 January, the High Court ruled in their favour, deleting the sentence in dispute, implying that the Commission should consider retaining the status quo, either in part or wholly, as an option as well.

The County Councils of Avon, Cleveland and Somerset sought judicial review to stop these proposals going forward, but the High Court found them within the law.

[25] The government accepted most of these recommendations, but also kept the status quo in Somerset ("after taking account of the number and strength of the representations which I received opposing the recommendations"), and in North Yorkshire retained a rump two-tier North Yorkshire without York ("in the light of the strong representations which I have received opposing the Commission's recommendations for North and West Riding") – both reportedly the subject of strong lobbying by local Conservative MPs.

[30] In final reports delivered in October 1994, the Commission recommended Buckinghamshire and Bedfordshire county councils be abolished and replaced with four and three unitary authorities respectively.

In other counties, it backed down from more radical draft proposals, and it recommended no change in Cambridgeshire, Cheshire, Cumbria, Lancashire, Kent and Oxfordshire.

[31][32][33][34] A further batch of reports was delivered in December, recommending that Norfolk, Northamptonshire, Northumberland, Suffolk, Surrey, Warwickshire, West Sussex should remained unchanged.

In Leicestershire, Leicester and Rutland would become unitary authorities, with the rest of the county remaining two-tier – a pattern followed also in County Durham (Darlington), Devon (Plymouth and Torbay), East Sussex (Brighton & Hove), Essex (Southend-on-Sea), Nottinghamshire (Nottingham), Staffordshire (Stoke-on-Trent) and Wiltshire (Thamesdown).

[36] In a January 1995 interview, Banham explained the decision-making process of the Commission was based strongly on local opinion, noting that although a fully unitary solution for much of the country would commend all-party support in the House of Commons, he thought it would cause "mayhem" when implemented.

Gummer identified as candidates on his 2 March statement the districts of Basildon, Blackburn, Blackpool, Broxtowe, Dartford, Exeter, Gedling, Gillingham, Gloucester, Gravesham, Halton, Huntingdonshire, Northampton, Peterborough, Rochester upon Medway, Rushcliffe, Thurrock, Warrington.

The Commission noted that tight boundaries for Norwich would cause a problem for unitary government, but that an extension would likely be strongly opposed.

The local government reform did not affect police areas, or fire and rescue service areas, but resulted in the setting of many more joint boards for such authorities: previously county councils were represented on these bodies, and the creation of new unitary authorities meant that the apportionment of representatives was adjusted.