Affordable Housing Statement content at ten units

At ten dwellings an Affordable Housing Statement stops being optional. Most local validation lists require one for major residential development, which national policy frames as 10 or more homes or a site of 0.5 hectares or more, and a missing statement is a straightforward reason for an application to be returned as invalid. The content is also more specific than applicants expect: a schedule of units by tenure and size, plot numbers on a plan, the delivery mechanism, and the heads of terms you expect to see in the section 106 agreement.

Write it as the document the housing officer will mark up, because that is exactly what happens to it.

Why the statement is a validation item

Validation is a two-part test. The national requirements are set out in legislation, and each authority publishes a local list of additional documents it needs. Affordable housing statements appear on most local lists for major schemes, sometimes with a stated content specification.

That has a practical consequence. A statement that exists but omits a required element can still fail validation, and the eight or thirteen week clock does not start until the application is valid. Checking the local list before you draft, rather than after a refusal to validate, is the best half hour you will spend on the project.

Rural areas complicate the threshold. In designated rural areas national policy allows authorities to apply a lower threshold, so a scheme of five or six dwellings can attract the full requirement. Read the adopted policy rather than assuming ten.

Policy requirement and the offer

Open with the arithmetic, stated plainly: the total number of homes, the policy percentage, the resulting number of affordable homes, and how rounding was handled. Rounding is a recurring argument on schemes just above the threshold, so show the calculation and say which way you rounded and why.

Then set out the offer against the requirement. Where the two match, say so in one sentence and move on. Where they do not, the statement has to explain the shortfall and signpost the evidence, which usually means a Viability Assessment prepared by a suitably qualified author and reviewed before submission.

Three details belong here rather than later:

• the proportion offered as affordable home ownership, where national policy expects a share on major sites
• any vacant building credit claimed, with the floorspace evidence behind it
• whether the offer is on-site, off-site or a payment, with the justification for anything other than on-site

Tenure mix and unit mix tables

Tables do the work in this document. Two are essential and a third helps.

The figures above are illustrative. Use your own schedule, keyed to plot numbers that appear on the submitted site layout, and give the floor area measured on the same basis as the rest of the application so nobody has to reconcile two sets of numbers.

A second table should set the offer against the authority's evidence of need, bedroom size by bedroom size. Housing officers assess mix against need, so a statement that only reports what you are building invites a request for more information. Where the scheme cannot deliver the needed sizes, say why by reference to the site rather than the business plan.

The third table, useful on anything phased, ties affordable units to phases and to trigger points for delivery. Phasing is where threshold arguments start, and our note on phasing a large scheme without gaming thresholds covers the line between programming and avoidance.

Clustering and tenure blind design

Policies commonly ask for affordable homes to be distributed across a site rather than grouped in one corner, and to be externally indistinguishable from market homes. Both points are assessed from the drawings, so the statement should point at the drawings rather than assert compliance.

Cover the external materials and detailing, whether entrances and bin and cycle stores are shared or separated, car parking allocation, and the route from the street to each front door. On flatted schemes, add the core arrangement and whether affordable and market homes share lifts and refuse arrangements.

Service charges matter more than they look. A shared ownership home in a block with a high service charge may fail an affordability test even where the capital cost works, and registered providers will raise it. A short paragraph on expected charges and what they cover saves a round of questions.

Accessibility standards sit alongside this. State which homes meet the optional Building Regulations accessibility requirements where the local plan applies them, with the numbers, since that interacts with the mix.

Where viability enters the statement

Keep viability contained. If the offer is policy compliant, viability has no place in the document at all, and raising it invites scrutiny you do not need.

Where the offer falls short, the statement should do three things and no more: state the shortfall, state that an appraisal accompanies the application, and summarise the conclusion in a sentence. The argument itself belongs in the appraisal, where the inputs can be evidenced and tested.

Expect the appraisal to be reviewed at your cost, and expect benchmark land value to be the main battleground. National guidance is clear that the price paid for land does not justify a reduced contribution, so an appraisal built on an acquisition priced at nil affordable housing will not survive review.

Where the authority is likely to require a review mechanism, saying so in the statement and setting out the structure you would accept is a sign of good faith that officers notice.

Registered provider engagement

A statement is stronger with evidence that someone will take the homes. Approach registered providers early, ask what they will buy and at what sizes, and record the response.

What to include:

1. Confirmation of which providers have been approached and when.
2. Any written expression of interest, with commercial figures redacted if necessary.
3. The providers' comments on unit sizes, service charges, parking and management arrangements.
4. Whether the authority has preferred providers or a nominations arrangement that affects design.
5. Your fallback position if no provider is secured before determination.

Providers routinely refuse small numbers of units in a block they will not manage, flats above commercial uses, and homes with unusual service charge exposure. Finding that out before the drawings are fixed is worth a fortnight of design time. Where the scheme also triggers self-build or custom-build duties, those obligations need coordinating too, and our note on self-build and custom-build duties on larger sites sets out how.

Common omissions that delay validation

The recurring gaps are mundane:

• no plan showing which plots are affordable, or plot numbers that do not match the layout drawing
• floor areas missing, or given on a different basis from the rest of the submission
• tenure described as "affordable" without specifying rent, intermediate or ownership product
• no heads of terms, so the authority cannot see what it would be securing
• silence on phasing and delivery triggers
• the statement contradicting the Design and Access Statement on parking or storey heights

Two checks close most of them. Read the statement against the site layout and the accommodation schedule, line by line, and read it against the local validation list with a pen. Then put the heads of terms on the last page as a short list: what, how much, when, and for how long.

An Affordable Housing Statement drafted this way does more than get an application validated. It gives the housing officer the schedule they need for their consultation response, which is the fastest route to a recommendation you can live with.

Browse all 66 PlanScope report types and start a draft while the accommodation schedule is still in flux, then send it for professional review. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.