Consultation response: National Planning Policy - consultation on proposed changes

By: John Bibby  Published: February 2016


This is a response to the Department for Communities and Local Government's consultation on changes to national planning policy.

Summary

The comments in this response focus exclusively on the proposal to amend the definition of affordable housing in planning policy as this is the part of the consultation that we are best-placed to comment on and have the most serious concerns about.

We are concerned that if the definition of affordable housing is amended as proposed, it will have the following consequences:

  • The public purse will get worse value for money, because it will require sustained investment to maintain a stock of homes that are only discounted temporarily
  • Government subsidy will be misdirected to those who don't need assistance to buy, due to the absence of any income-related eligibility criteria for Starter Homes
  • It will be more difficult for planning authorities to deliver homes that people on low to middle incomes can actually afford, because the link between types of affordable housing and incomes will be further diluted

We also believe that the equality statement that was released with the consultation document has underestimated the potential impact of the proposed change on protected characteristics. This is because it only considers the initial impact instead of what the impact will be over the long-term. As an example, we show that the negative impact on disabled households for every hundred homes over a thirty year period increases from 25-32 to 65-83 households who are unable to access an affordable home.

We urge the government to make the following changes to its current approach:

  • Retain the principle of affordable homes remaining as such in perpetuity/for subsidy to be recycled on sale; And maintain a link with income in eligibility criteria for affordable housing
  • If the above is considered unacceptable given existing commitments on Starter Homes, to make the Starter Homes policy an explicit exception from the normal definition of affordable homes
  • Take this review as an opportunity to reintroduce a greater link between the definition of affordable housing and  local incomes
  • Revise the equality assessment of the Starter Homes policy to estimate the long-term impact of the policy on the protected characteristics

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