Section outline: affordable housing statement for 12 units

At twelve dwellings you are over the major development threshold, so the affordable housing policy in the adopted local plan is engaged and an affordable housing statement outline needs to do real work rather than confirm a nil contribution. The Framework's position is that affordable housing should not be sought from developments that are not major development, meaning fewer than ten homes, except in designated rural areas where an authority may apply a lower threshold. Twelve units clears it, and the statement has to say what is being provided, where it sits in the scheme and how it will be secured.

The outline below follows the order officers read in. Each section is short. The document as a whole should run to six or eight pages, not thirty.

Policy requirement and the threshold engaged

Open with the arithmetic and the policy references. State the number of dwellings, the site area, and the fact that the scheme is major development because it exceeds ten units. Then cite the affordable housing policy in the adopted local plan by number, quote the percentage it requires and the tenure split it specifies, and note any supplementary planning document that sets out how the policy is applied.

Cover three further points here.

• Whether the site lies in a designated rural area where a lower threshold applies.
• Whether the council applies a First Homes requirement to part of the affordable provision, and what proportion.
• Whether any vacant building credit is claimed, and on what basis.

A statement that opens with a paragraph about the importance of affordable housing, rather than with the policy percentage and the resulting number of units, has wasted its first page.

Scheme description and unit mix

A short table beats prose. Give the total number of dwellings, the split by number of bedrooms, the gross internal area of each type, whether each is a house or a flat, and the parking allocated.

Then give the same information for the affordable units specifically, so the reader can see the mix without doing subtraction. Twelve units at a policy requirement of 35 per cent produces 4.2 affordable homes, and how that fraction is dealt with matters. Say whether you propose four units with a commuted sum for the remainder, five units, or four units and a policy argument. Do not leave the rounding unexplained, because the officer will assume the least generous reading.

Cross-refer the unit numbers to the plot numbers on the submitted layout, and keep those numbers consistent with the Design and Access Statement and the section 106 draft. Inconsistent plot numbering between documents is the most common cause of a legal agreement taking three months.

Proposed affordable provision and tenure

Set out the tenure of each affordable unit using the categories in the Framework's own definition: affordable housing for rent, discounted market sales housing, and other affordable routes to home ownership including shared ownership and First Homes.

Where the policy tenure split cannot be met, say which element is short and why, rather than presenting a different split as though it complied. Officers compare the table with the policy line by line.

Location and distribution within the site

Councils expect affordable homes to be distributed rather than grouped in one corner, and they expect them to be indistinguishable from the market units in external appearance. That is the tenure blind principle, and it is tested on the drawings.

Explain four things. Where the affordable units sit, by plot number, shown on a plan with a clear key. How they are distributed across the site. Why any clustering exists, since registered providers often prefer small groups for management reasons and that is a legitimate answer if stated. And how materials, boundary treatments, refuse storage and parking are handled identically to the market units.

Watch the practical details, because they are what a provider rejects a scheme on. Affordable units at the back of a shared parking court with the bin store outside their windows will read as second class however matched the brickwork is.

Registered provider engagement

This is the section most statements skip and most officers value. It shows that the provision is deliverable rather than notional.

Record which registered providers have been approached and when, whether any has expressed interest, and what requirements they have set. Providers commonly specify a minimum cluster size for management, a preferred bedroom mix, space and accessibility standards above the local policy minimum, no leasehold flats above commercial premises, separate stair cores, and a service charge cap. Where a provider has declined the scheme, say so and give the reason, because that is material to the tenure argument you are making.

If no provider has yet been approached, say that too, and set out when you will. An unevidenced assertion that a provider will take the units is worth nothing at committee.

Where provision is reduced and why

If the scheme proposes less than policy, this section carries the application. Set out the policy requirement, the provision offered, the shortfall in units, and the reasons.

Legitimate reasons are few and specific. A registered provider will not take units of the type the site can deliver. The site's abnormal costs are such that policy-compliant provision cannot be supported. A commuted sum is proposed because on-site provision is impractical for a stated physical reason. What will not carry weight is a general assertion that the scheme is marginal, or a land price paid on the assumption of nil affordable housing.

Be explicit about which of these you rely on, and cross-refer to the evidence. A reduction argued in this section but evidenced nowhere is a reduction the officer will recommend refusing.

Viability evidence where it is relied on

The Framework and the Planning Practice Guidance on viability set a plan-led approach: viability is assessed when the plan is made, and the price paid for land is not a justification for failing to comply with policy. Viability at application stage carries weight only where circumstances justify revisiting it, and the burden is on the applicant.

Where an appraisal is submitted, it should follow the guidance and the relevant professional standard on financial viability in planning, state the benchmark land value and how it was derived, state the gross development value, build costs, professional fees, finance and developer return assumptions, and be submitted on the basis that it will be published. A Viability Assessment of this kind usually needs a suitably qualified author, and councils commonly instruct their own reviewer at the applicant's cost.

Consider whether a review mechanism is a better answer than a reduced figure. An early stage review clause in the agreement, triggered if the scheme is not substantially begun within a stated period, gives the council comfort and keeps the permission moving.

Securing provision through the agreement

Provision is delivered by a planning obligation under section 106 of the Town and Country Planning Act 1990, so draft the heads of terms and include them as an appendix.

The terms that matter are the number and tenure of units by plot number, the transfer mechanism and price basis to a registered provider, nomination rights for the council, the trigger points linking affordable delivery to market occupation, restrictions on occupation until transfer, a mortgagee in possession clause, and a cascade mechanism setting out what happens if no provider acquires the units. Where a commuted sum is proposed, state the amount, the calculation basis, the indexation and the payment trigger.

Get the draft to the council's legal team early. A Planning Statement and an affordable housing statement that already contain agreed heads of terms shorten the period between resolution and decision considerably, and that period is where minor schemes lose months. The same discipline of writing a document the reader can convert directly into a condition or a clause applies to the technical reports, as set out in the guide to the sections an officer checks in a BS 4142 noise report.

Enter your postcode on PlanScope to see which documents a twelve-unit scheme is likely to need.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.