Published: 19 Sept 2019 by Cecil Sagoe

Here at Shelter, we want to see the introduction of reforms that will help deliver more social housing.

Planning reforms have a role to play in this. Especially reforms that provide the system with strength, greater clarity and, crucially, can empower the system to secure more high-quality social housing.

But, as highlighted in the first blog in our series on the planning system, planning deregulation is not the way forward. This is something the blogs will explain in more detail, also highlighting reforms that could enable the system to secure the social housing we need.

For this post, we’ll be focusing on reforms that need to be made to existing exemptions in place for small sites.

Our housing crisis

It’s no secret that we’re deep in the midst of a long-term housing crisis. There are nearly 277,000 people recorded as homeless in England. The need for new, high-quality social housing is urgent.

Despite this, of the 222,000 new homes delivered last year, only 6,500 were social rent homes.

We desperately need all parts of the system and all types of development to be contributing to social housing delivery. But our planning system grants exemptions to some types of development.

Social housing exemptions

Last week, we discussed the social housing get-out clause that exists within the permitted development system. However, national planning policy also allows two other types of housing development to avoid contributing towards social housing delivery.

Firstly, Vacant Building Credit provides certain exemptions from affordable and social housing contributions for vacant buildings that are brought back into use.

Secondly – and the subject of this blog – there is an exemption for housing developments taking place on small sites. As we will explain below, if government removed this exemption, they could boost delivery of the social housing we so desperately need.

Small sites exemption

National Planning Practice Guidance set out in 2016 stipulated that local authorities should not seek affordable housing contributions from housing developments that are providing 10 or fewer homes, and comprise no more than 1,000sqm of floor space. In designated rural areas, for instance National Parks, local authorities are able to lower the threshold to five homes or fewer.

The rationale the government set out when introducing this policy was the ‘disproportionate burden of developer contributions’ on small-scale development. The idea is that affordable housing contributions, which include social housing contributions, constitute a cost so big to developers of small sites that it can ‘stop them from building any homes at all’.

Despite the introduction of government’s policy, the Planning Inspectorate clarified that this policy can be overridden if local authorities are able to produce extremely strong evidence that supports the establishment of a lower threshold. Subsequently, local authorities such as Cornwall have adopted policies indicating that it is entirely feasible to get affordable housing contributions from small sites. Indeed, in many areas it’s social housing that’s actually needed, rather than expensive private developments that many local people cannot afford.

However, most local authorities have taken government’s guidance as a signal that affordable housing contributions should not be acquired from housing schemes below the government’s threshold.

Government’s policy has therefore brought in a new norm: it is entirely unreasonable to expect affordable housing contributions from small sites, even if it is entirely possible to get these contributions, and even if they’re what are desperately needed in the area.

This small sites exemption policy makes tackling homeless especially difficult for areas reliant on small sites for housing delivery. This includes rural areas where small sites often make a significant contribution to housing supply.

Moreover, government’s policy has enabled perverse behaviour. Expert research into housing delivery in England has indicated that some developers are choosing to deliver nine units or less as a result of government’s 10-unit threshold policy for affordable housing contributions.

Government’s policy is not only making it more difficult for local authorities to secure affordable housing contributions from small sites, it is also inhibiting major housing schemes from coming forward, which are normally expected to provide social and affordable housing.

We need contributions from small sites

The acute extent of social housing need in England demands a fundamental change to government’s policy approach to small sites. This is especially the case in a context where small sites will continue to be an important source of overall housing supply.

Some local authorities are leading the way in thinking about the sorts of contributions that we should be expecting from small sites. But it is also imperative that we get a policy change from government in order to provide certainty that social and affordable housing contributions will be expected from small sites.

We believe small sites can deliver social housing directly. This will be made easier if government implemented the land reform we’re calling for (a topic we will tackle in the next post in this series of blogs) and through long-term government investment in social housing.

As a second option, small sites could be required to make financial contributions to a ‘donor’ site, which would boost social housing levels on that site.

But, at the heart of a reformed approach to small sites must be the principles that:

• they, along with major sites, should be expected to contribute to social housing delivery
• local plans must provide clarity over the level of social housing contributions that small sites should make

If we’re to deliver the three million social homes that we need, then we need all sites possible to deliver, large and small. You can demand that government builds more social housing by signing this petition.