Affordable Housing SPD frequently asked questions
Alongside the consultation on the draft SPD, we have produced a series of commonly asked questions about the topic. These are intended to put the draft SPD into context, and highlight some of the other work that is happening to prioritise delivery of affordable housing.
Why has the Council decided to update the Affordable Housing SPD?
The previous Affordable Housing SPD was adopted in 2014. The document contained advice and guidance to be addressed in all proposals for new development or changes of use for wholly residential and mixed-use sites incorporating residential use. The main updates within the new SPD relate to how the Council will assess viability during a planning application and how we will use viability review mechanisms. Since the adoption of the previous SPD there have been various changes in policy and guidance at both a national and regional level on how viability should be assessed. We therefore decided that it was pertinent to bring our own guidance in line with these changes. The consultation is on the whole draft SPD; anyone can comment on any part of it.
Who is this document for?
This document will help all parties involved, such as the Council, landowners, developers and registered providers, deliver affordable housing through new development. The consultation is open to anyone, but is aimed at those who will use the SPD to inform the planning applications they submit to the Council, i.e. consultants, developers or landowners.
We want to enable residents to get involved in local matters and the planning process, including on affordable housing. It should however be noted that the document contains quite technical advice and guidance, which may be easier to understand for qualified professionals. The SPD emphasises the principle of transparency, which means all the information submitted by an applicant regarding viability will be available for the public to view and comment on as part of the planning application process.
Does the Affordable Housing SPD create new policy?
The SPD does not create any new policy in relation to affordable housing; in fact, no SPD can create policy – the purpose of it is to provide guidance to supplement adopted policies. Its purpose is to provide guidance on the current affordable housing policy within the existing Local Plan (2018), Policy LP 36. The aim is to give clarity to both applicants and residents on how the Council will apply Policy LP 36, and what is required to meet the requirements within the policy.
Although SPDs cannot create new policy, they are a material planning consideration when the Council (as the decision maker) determines a planning application.
Will this document lead to more affordable housing being delivered in Richmond?
This SPD relates to affordable housing that is provided through the planning system, which is commonly referred to as planning gain. The SPD explains that affordable housing is defined nationally and there are different products within that, comprising both affordability and eligibility.
Due to changes at national policy level, Councils must take into account whether the delivery of a site at a policy compliant level of affordable housing (for example the strategic boroughwide target of 50% of units) is economically viable for a developer to bring forward (contained with Policy LP 36). The review of viability information is commonly referred to as a Financial Viability Assessment (FVA). It is this part of the planning process that the changes to the revised SPD have focussed on. It will bring the Council in line with the most up to date guidance on the subject of viability. By having a robust process setting out exactly what the Council requires as part of a FVA will allow us to be certain that we have done everything in our powers to assess the viability of each scheme and make sure that maximum amount of affordable housing is being delivered on each site.
We are also using our own funding to help deliver affordable housing through our connections with Registered Providers (commonly referred to as ‘RPs’). Read more details of these schemes.
It is worth noting that affordable housing is a key priority for us as a Council. There are also other important policy requirements in the whole of the Local Plan, such as ensuring new development is built to the highest sustainability standards given the climate emergency. The Plan seeks land uses which meet future needs for housing, employment and other community and infrastructure services. All of these factors are taken into account when site-specific development proposals are assessed. The reality is that many sites in Richmond borough have constraints, and planning is often about balancing competing needs.
Why does the Council ask for affordable housing contributions on sites below 10 units?
We are already undertaking a review of the adopted Local Plan – you can read about the Draft Local Plan and the stage this has reached, and find about the opportunity to get involved in the next round of consultation. You can also find about our housing strategies and policies which inform the planning approach.
Isn't the government about to change the system for securing financial contributions and affordable housing from new developments?
The Government has recently published the Levelling Up and Regeneration Bill, which sets out the framework for a new Infrastructure Levy, to largely replace the current system of obtaining developer contributions for infrastructure and affordable housing. However, there will be further regulations and it is not certain at this point in time when this will come into effect; the rollout could potentially be over several years. In the meantime, the current system of securing financial contributions remains.
Updated: 17 June 2022