Consultation paper - influencing the size, type and affordability of housing. Available to members only.
Introduction
We have already circulated the headline details of the statement on planning issues made by Keith Hill on 17 July 2003. This note focuses in more detail on those aspects of the Minister’s statement concerning the provision of affordable housing.
The ODPM’s consultation paper on this issue concerns a proposed change to PPG3 regarding the provision of affordable housing (AH) through the planning system. The proposed change will replace paragraphs 9-20, 71 and Annex B of PPG3. Circular 6/98 will be cancelled. The update will be accompanied by practice guidance, which has yet to be issued.
The deadline for responses to the consultation is 31 October 2003.
Detail
The key proposals in the consultation paper are:
1. Regional planning bodies to maintain an up-to-date understanding of the regional housing requirement, which is to include annual rates of provision, types and sizes of accommodation and appropriate sub-regional analysis.
2. LPAs to define AH in terms of the relationship between local income levels and house prices or rents based on an up-to-date assessment of needs. Can refer to identified groups, such as key workers, but not to specific tenure unless this would address an identified need that would not be met by other types of AH.
3. LPAs to assess the full range of AH required and set targets that are achievable within the planned overall levels of housing provision.
4. LPAs to identify sites on which AH will be expected (as part of residential or mixed-use development) and indicate the amount of AH to be sought.
5. AH provision should not make development unviable taking into consideration:
· costs of bringing sites to the market
· availability of public subsidy
· avoiding prescription of tenure
6. LPAs will not need to depart from adopted policies that take account of this PPG unless the applicant can demonstrate that site constraints, or other plan requirements, would make the provision of AH unviable.
7. AH should not normally be sought on sites of less than 0.5 ha or 15 dwellings. If AH is sought on smaller sites LPAs must demonstrate
· an increased overall supply of AH will result
· no adverse affect on the overall supply and pace of housing
8. Presumption that AH should be provided on-site except in a limited number of circumstances where the LPA and developer consider a financial payment or off-site provision is preferable. Possible circumstances include where:
· AH is more effectively secured by re-use of existing stock
· on-site management cannot be secured effectively
· this would widen housing choice and encourage better social mix
9. AH in rural areas may be supported by allocating sites solely for AH on land within or adjoining existing villages, which would not otherwise be released for housing.
10. This policy will immediately be a material consideration that may supersede local plan policies before they can be reviewed.
HBF Comment
The aim of the Government is to secure more affordable housing without affecting the overall supply of housing. However, this consultation paper proposes strengthening the role of LPAs in the provision of affordable housing and given the general difficulties in obtaining planning consents, the implication is that this will further deter development opportunities and constrain supply.
The specific concerns are:
· The ability of LPAs to address an identified need will inevitably lead to LPAs stressing the role of social rented housing. Circular 6/98 was much more robust here by stating that planning policy should not be expressed in favour of any particular form of tenure.
· As the policy retains an emphasis on LPAs assessing affordable housing needs only, rather than an assessment of overall housing needs, housing needs surveys will continue to focus upon the provision of social rented housing.
· Although the policy states that AH provision should not make development unviable, the onus is upon the developer to demonstrate this, which is likely to lead to the adoption of excessive affordable housing requirements, pressure for open book accounting and delays in the planning process.
· The loose reference to availability of public subsidy gives LPAs the opportunity to keep levels of public subsidy at a minimum, as it is the developer who will need to demonstrate that levels of public subsidy and affordable housing requirements are incompatible.
· The policy removes the restriction in Circular 6/98 that prevents LPAs prescribing which partners developers should use to deliver affordable housing. This is strengthening the role of LPAs in delivery.
· The reference to thresholds enables LPAs to demonstrate a need for thresholds below 0.5ha or 15 dwellings, with no lower limit. This effectively removes thresholds from affordable housing provision. Circular 6/98 was more definitive in setting thresholds by allowing the possibility for LPAs to set a lower threshold, but at a minimum level of 0.5ha or 15 dwellings.
· As the policy is to be a material planning consideration that may supersede plan policies it will have an immediate impact in the development process. Of particular concern is the effect on sites where options have been calculated on existing planning policies. In particular the reduction in thresholds will require the provision of AH on smaller sites that are currently exempt.
· The broad reference to meeting the planning requirement of the whole community is open to abuse. It is likely that the LPA will initially focus upon social rented needs rather than a more balanced provision across the affordable housing spectrum.
The Way Forward
The HBF’s response to this consultation paper will be put together through the Affordable Housing Working Group, which shall be meeting in August to consider this matter. A draft HBF response will be available by mid-September. Those member companies that respond to the consultation on an individual basis are encouraged to consider this response in the interests of achieving a consistent co-ordinated industry response.
James McConnell
Strategic Planning Co-ordinator