Waverley Borough Council Home Page Waverley Borough Council Home Page

Waverley Borough Council Committee System - Committee Document

Meeting of the Executive held on 30/09/2003

Summary & Purpose
This report presents a Government consultation paper “Influencing the size, type and affordability of housing”. The proposals would replace parts of Planning Policy Guidance Note 3 Housing, and Circular 6/98 Planning and Affordable Housing, which would be cancelled. The objective is to increase the supply of affordable housing through the planning system, and ensure that the size and type of housing better matches need. This report summarises the key changes. The proposed changes themselves are set out in full at Annexe 1. A recommended response, to be forwarded to the Executive for decision, is at Annexe 4. The key points in the response are summarised at paragraph 7 of the report.

Quality of Life Implications
Natural Resource Use
Pollution Prevention and Control
Biodiversity and Nature
Local Environment
Social Inclusion
Safe Communities
Local Economy
Resource Use
Prevention and Control
and Nature
Safe, Healthy
and Active

The changes will potentially increase the amount of affordable housing secured through the planning system.

E-Government implications:
The consultation documents are available from the Office for the Deputy Prime Minister at www.ODPM.gov.uk

Resource and legal implications:
There are no legal implications. Resource implications are difficult to predict. The amount of public subsidy available to Waverley to fund affordable housing is currently unknown. If there is insufficient Government funding to maximise the delivery of affordable housing, the Council could decide to make its own resources available through the review of its Financial Strategy, although capital receipts pooling and the withdrawal of Local Authority Social Housing Grant from 1st April 2003 will seriously restrict this option. If public subsidy is insufficient for a particular scheme it might be necessary to accept units fully funded from the developer. However, this would restrict the number of affordable homes built. Amending the Council’s planning policy in line with changes to Government policy will itself have a resource implication, but this could be absorbed into a wider review of the Local Plan. The added emphasis on a proper evidence base and assessment may also give rise to pressure on resources.


1. The Government has published two consultation papers proposing changes to Planning Policy Guidance Note 3 Housing. “Influencing the size, type and affordability of housing” is the subject of this report. The other paper, titled “Supporting the Delivery of New Housing” addresses the release of employment sites for housing, and will be the subject of a separate report to the Executive. The deadline for responses is 31st October 2003.

2. The aim of the proposals in “Influencing the size, type and affordability of housing” is a policy framework that will secure more affordable housing and a better match between the housing planned and the needs of the community. The changes will be accompanied by practice guidance, and together they will replace the relevant parts of PPG3 (Housing) and Circular 6/98 (Planning and Affordable Housing), which will be cancelled. This is a new approach designed to give a clearer distinction between ‘policy’ and ‘advice on implementation’. Annexe 1 contains the proposed changes themselves, with a draft framework of the practice guide at Annexe 2.


3. The Government promised changes to planning policy back in February 2003 as part of a package of proposals announced in Sustainable Communities: Building a Better Future (The Communities Plan). In March 2003, both the Environment and the Community Overview and Scrutiny Committees considered whether to review Waverley’s planning policies on affordable housing. The Government’s promise to review national planning policy, and uncertainty over future levels of public funding, provided an unstable basis on which to review local planning policy. Officers were asked to look further into the opportunities offered within the ‘Communities Plan’.

4. The current consultation indicates the Government’s latest thinking on planning policy. Details of the new funding regime, and implications for Waverley, are still awaited, and could impact on the ability to deliver affordable housing. The funding shake-up at national level could influence this Council when considering its own Financial Strategy, which could influence the delivery affordable housing.

The consultation

5. Annexe 1 sets out the proposed changes in full. The key changes proposed are:

1) A greater emphasis on regional and sub-regional planning. Housing markets tend to operate at a sub-regional level, rather than within local authority boundaries. Regional Planning Bodies and Regional Housing Boards will work closely to link Regional Housing Strategies with Regional Spatial Strategies.

2) The basic minimum site size threshold of 1 hectare/25 dwellings, contained within Circular 6/98 is reduced to 0.5 hectares/15 dwellings. Circular 6/98 already allows this lower threshold provided local authorities can justify it (as this Council succeeded in doing at the last Local Plan Inquiry).

3) Thresholds below 0.5ha/15 dwellings will be permitted where justified. Thresholds below 0.5ha/15 dwellings are currently accepted under Circular 6/98, where justified, but only in settlements with a population of less than 3,000 (this Council has a low threshold of 0.2Ha/5 dwellings in the smaller settlements). The new policy makes no reference to settlement size. This is an important point because local planning authorities will be able to adopt lower thresholds, where justified, regardless of settlement size. Currently, under Circular 6/98, the lower threshold cannot be applied in Farnham, Godalming, Haslemere, Cranleigh and Milford.

4) Allocating sites solely for affordable housing on land within or adjoining existing villages. This change relates to types of site currently referred to as “rural exception sites”, where development would not otherwise be permitted, except solely for affordable housing. Currently these sites come forward on an ad hoc basis, and are not identified in the Local Plan, thus keeping the land value down. This “exceptions” approach is explicitly legitimised in national policy at paragraph 18 of PPG3. The Government’s new policy will involve identifying such sites “up front” in the Local Development Framework. Land values will be kept low by restricting development solely to affordable housing. This has the benefit of added certainty for Housing Associations and the public about where affordable housing will be provided. The new policy makes no reference to “exception sites” as they are currently understood, so presumably “unallocated” exception sites would no longer enjoy a legitimacy spelled out in national policy.

6. The Government present their proposals as the second of three options, summarised below. The table at Annexe 3 is taken from the consultation paper, and summarises the costs and benefits of each approach.

Response to consultation

7. Option 2 is favoured since it will allow local authorities to tailor policy to local circumstances, and thereby maximise affordable housing delivery. The Government has asked a number of specific questions as well as inviting general comments. Annexe 4 sets out the questions with an officer response. The key responses are:

1) The reduction in the minimum site size threshold from 1Ha/25 dwellings to 0.5Ha/15 dwellings is disappointing bearing in mind the statistic in the “Communities Plan” that almost 80% of housing sites in the South East are less than 0.5 hectares. Circular 6/98 already allows for this threshold where justified and many authorities, including Waverley, are already applying it. 2) Removing the distinction in policy between settlements above 3,000 population and those below 3,000 is supported. This enables local planning authorities to seek thresholds below 0.5ha/15 dwellings regardless of settlement size. In fact, this change begs the question whether national planning policy should specify a minimum threshold at all. Local authorities should be free to set their own thresholds according to local circumstances, provided they can demonstrate that their policies will result in an increased supply of affordable housing, with no adverse effect on the supply of housing generally. 3) If a threshold is to be quoted, it should be clear whether the site area is net or gross, and whether the number of dwellings is net or gross. 4) The Practice Guide should address the problem that development proposals can be tailored to fall just below the threshold. The nature of the threshold encourages developers to provide, say, 14 market dwellings, rather than potentially provide 15 or more, with affordable housing included. Some sort of sliding scale approach should be devised. This would encourage optimum use of sites, and increase the supply of affordable housing. 5) Bringing more sites into the remit of affordable housing policy, via lower thresholds, will have less effect than desired if there is insufficient public subsidy to maximise affordable housing on development sites. The Government is urged to make sufficient public subsidy available to enable local authorities to secure the maximum number of affordable homes on development sites. Without public subsidy, fewer affordable homes can be achieved on “quota” sites. 6) The Government’s Planning Green Paper (December 2001) proposed a tariff system that would enable contributions to affordable housing from commercial development. This was an interesting idea that Waverley Borough Council supported. At a time when ways are being sought to deliver affordable housing without public subsidy, it is disappointing to see this option closed off.

7) The proposal to allocate land within or adjoining villages solely for affordable housing is supported. However, the wording must ensure that “quota” sites, (those that include market housing) are not permitted on the basis that part of the development would contribute to meeting local housing need. The second and third sentences at paragraph 16 are not entirely clear in this respect. 8) The “exceptions” policy that currently exists should remain valid to allow for unallocated sites to be developed under exceptional circumstances. Such sites may not be allocated in the Plan if, for example, a landowner ‘holds out’ for market housing. Only when the market housing option is closed off, and the Plan adopted, might the owner then be willing to relinquish the site at a lower price, solely for affordable housing. 9) The “allocations solely for affordable housing” approach is aimed at rural areas, but specifically refers to “villages”. The draft does not define a village for the purpose of the policy, but more to the point, many market towns also have an acute shortage of affordable homes, with insufficient windfall “quota” sites to meet affordable housing needs. In circumstances such as these, the policy should allow sites solely for affordable housing to be allocated, and/or permitted under the current “exceptions” rule, at towns as well as villages.

Environment and Leisure Overview and Scrutiny

The Environment and Leisure Overview and Scrutiny Committee considered this report at its meeting on the 15th September 2003. It agreed with most of the officer responses to the Government consultation at Annexe 4, but made the following comments.

In respect of Question 1, the Committee disagreed with a greater role being given for regional and sub-regional planning, emphasising that local issues must come first, with a firm desire to retain control locally. The committee questioned whether housing markets necessarily reflect regional boundaries any better than local authority boundaries.

In respect of Question 2, the Committee agreed that the drop in threshold to 0.5ha/15 dwellings was disappointing, but went on to suggest that a lower threshold of 0.2ha/5 dwellings should be explicitly stated (this is the threshold in the Waverley Borough Local Plan as applied to settlements of less than 3,000 population).

Also in respect of Question 2, the Committee suggests that ‘net’ figures are used in the policy guidance, as they are in the Local Plan, rather than ‘gross’.

In respect of Question 3c, members recognise that ‘income’, especially in relation to local house prices and cost of living, is a relevant factor to be balanced with occupation in determining whether someone should qualify as a ‘key worker’.


It is recommended that

1. the comments of the Environment and Leisure Overview and Scrutiny Committee detailed above be included in the Council’s response; and 2. Annexe 4 to this report forms the Council’s response to the Government’s consultation paper “Influencing the size, type and affordability of housing”.

Background Papers
Consultation Paper on a Proposed Change to Planning Policy Guidance Note 3 Housing: Influencing the size and type and affordability of housing (July 2003)
Planning Policy Guidance Note 3: Housing
Circular 6/98: Planning and Affordable Housing


Name: Daniel Hawes Telephone: 01483 523295
E-mail: dhawes@waverley.gov.uk