Deliverability and phasing in an affordable housing statement

A policy-compliant tenure split means nothing if the statement cannot show who will take the affordable homes and when they will be built. The deliverability and phasing section is where an affordable housing statement either closes the argument or opens it, and officers read it before they read the policy compliance table. What they want is a named registered provider interested in the scheme, trigger points tied to market completions, and a layout that an affordable housing manager would actually accept.

Deliverability failures are rarely about numbers. They are about management: service charges a registered provider will not pass on, blocks with a single core serving a handful of affordable flats, or phasing that leaves the affordable units in a final phase that may never happen.

What deliverability has to demonstrate

Four things, in order of how often they are missed.

That a registered provider will take the units, evidenced rather than asserted. That the dwellings are acceptable to that provider in size, type, service charge and management terms. That the phasing delivers them alongside the market housing rather than after it. And that the section 106 obligation will bite at points that can be identified and certified without argument.

A statement that covers tenure split and unit numbers and then stops at "the affordable units will be transferred to a registered provider" has not addressed any of them. The Affordable Housing Statement is also the document a viability case has to be consistent with, so if a reduced offer is being made, the deliverability section has to explain what the offer is rather than leaving the reader to infer it from an appraisal.

Registered provider engagement and evidence of it

Evidence sits on a scale, and officers know the difference between the rungs.

Expressions of interest are the normal standard for a planning application, and they carry conditions. A provider will say it is interested subject to unit mix, service charge, parking, lift provision and nomination arrangements, and those conditions are the useful part of the letter. Quote them. An officer reading a conditional letter learns more about deliverability than one reading an unconditional sentence.

Where grant funding is assumed, say so and say what stage the application has reached, because an offer that depends on grant that has not been applied for is an assumption rather than a plan.

Phasing and the delivery trigger points

Triggers are the mechanism, and the drafting is specific. Common forms:

1. The affordable units in each phase to be completed before occupation of a stated proportion of the market units in that phase.
2. No occupation of any market dwelling until the affordable units have been transferred to the provider.
3. Affordable dwellings to be completed and transferred before occupation of a stated numbered plot.
4. A long-stop date, after which transfer must occur regardless of market build rate.

Option one is the usual landing point on a phased site. The proportion matters more than the principle: a trigger at 75 per cent of market completions in a phase leaves the council very little hold, and councils are increasingly asking for earlier triggers on sites where delivery has stalled before.

Where a site is phased over years, say which phase the affordable homes sit in and why. Putting all of them in phase three, with a trigger tied to phase three completions, is a deliverability problem dressed as a programme.

Distribution and integration across the site

Policy usually asks for affordable homes to be distributed rather than concentrated. Registered providers usually prefer clusters, because management, repairs and service charge apportionment are simpler. Both positions are reasonable, which is why the statement should explain the resolution rather than pretend the tension does not exist.

What works in practice is small clusters, several of them, each in a position with the same aspect and outlook as nearby market homes. On an apartment scheme the practical constraint is the core: a provider will not take six flats spread across four cores, because the service charge apportionment becomes unmanageable.

Tenure blind design and management arrangements

Tenure blind means the affordable homes are not identifiable from outside. Same materials, same window proportions, same boundary treatment, same bin and cycle storage standard, and no separate secondary entrance for affordable occupiers.

Management arrangements then need stating: who maintains the communal areas, how the estate management company and the provider interact, whether the provider adopts the landscape or pays into a management charge, and who holds nomination rights with the authority. Those details belong in the statement because they appear in the deed, and a mismatch between the two is a drafting problem that surfaces late.

Service charges and their effect on deliverability

This is the quiet killer of affordable delivery on apartment schemes. A building with a lift, a concierge, mechanical ventilation, a green roof and a basement car park carries a service charge that a shared ownership purchaser on a modest income cannot afford, and providers refuse units on that basis.

Three design decisions drive it: the number of flats sharing each lift and core, the extent of mechanical plant serving communal areas, and the amount of communal external space requiring maintenance. If the affordable units sit in the part of the scheme with the heaviest communal provision, expect the provider's letter to say so.

The honest response is to model the likely service charge early and locate the affordable homes where it is lowest, then say in the statement that this is what has been done and why.

Aligning the statement with the obligation

The statement and the section 106 agreement have to use the same definitions. Mismatches that cause trouble later:

• Different definitions of affordable housing tenures, particularly where a new tenure is involved
• Floor areas in the statement that do not match the schedule in the deed
• Triggers described loosely in the statement and precisely in the deed, or the reverse
• A cascade mechanism in the deed, allowing conversion to another tenure or a commuted sum if no provider acquires, that the statement does not mention
• Mortgagee exclusion clauses that change what the provider is actually taking

Cascade provisions deserve a paragraph of their own in the statement. They are reasonable protections for the developer and they are also the route by which affordable housing disappears, so a council will want the trigger period and the fallback stated openly rather than discovered in clause 14.

Where viability is doing work in the argument, the appraisal and its sensitivity testing have to support the delivery story; there is a separate piece on sensitivity testing in a viability appraisal, and the Viability Assessment itself should be consistent with what the affordable housing statement promises.

Browse the report types to see what a major residential application usually needs alongside the affordable housing statement.

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