Emerging Bristol Affordable Housing Policy VS Adopted

The current Bristol Core Strategy was adopted back in June 2011. A recent draft local plan was released (November 2023) with formative policies for the future.

 There are some notable differences in approach which may have implications for your development in the near future.

Current Adopted Policy

Policy BCS17 of the current Core Strategy sets out the expectations for Affordable Housing in the area, this can be seen below:

BCS17 Policy

Affordable housing will be required in residential developments of 15 dwellings or more. The following percentage targets will be sought through negotiation:

- 40% in North West, Inner West and Inner East Bristol;

- 30% in all other locations;

In residential developments below 15 dwellings an appropriate contribution towards the provision of affordable housing may be sought (either as a financial contribution or as on site provision) in accordance with any relevant policy in the Site Allocations & Development Management Development Plan Document.

Residential developments should provide a mix of affordable housing units and contribute to the creation of mixed, balanced and inclusive communities. The tenure, size and type of affordable units will reflect identified needs, site suitability and economic viability.

All units provided should remain at an affordable price for future eligible households or, if this restriction is lifted, for the subsidy to be recycled for alternative affordable housing provision.

Where scheme viability may be affected, developers will be expected to provide full development appraisals to demonstrate an alternative affordable housing provision.

The above identifies that depending on the location of the development, the percentage of affordable housing requested will be different. However, the threshold of 15+ dwellings remains the same.

In North West, Inner West and Inner East Bristol, 40% of the total number of dwellings will be sought and in all other locations, only 30% will be. Ideally, this provision should be on-site.

The map below shows the specific areas and the percentage requirements:

However, there are separate requirements for schemes of 10-14 dwellings – this is shown in the Site Allocations & Development Management Policies (July 2014).

For sites in Inner West, Inner East and South Bristol, the sought amount is 20%, whereas those in North West, East and North Bristol seek only 10%. This can be provided as either on-site or as a financial contribution in lieu.

The map below shows the specific areas and the percentage requirements:

All of the above percentages are subject to viability.

What's changed?

The adopted Affordable Housing policy is noticeably different to what is proposed in the publication Bristol Local Plan (November 2023).

Policy AH1: Affordable Housing Delivery can be seen below:

Affordable housing delivery

Affordable housing will be delivered through a range of delivery mechanisms including :

- Direct development of homes by Bristol City Council (new council homes);

- Development by the council's housing company Goram Homes;

- Direct development by Bristol City Council's registered provider partners and other affordable and specialist housing providers;

- Private residential development proposals where a proportion of each major development will be delivered as affordable housing, including a proportion delivered without subsidy.

Residential developments of 10 dwellings or more that are subject to this policy will be expected to provide at least 35% affordable housing as part of the dwelling mix.

Proposals should be designed at the application stage to deliver the expected proportion of at least 35% affordable housing.

To demonstrate how this will be achieved developers should :

- Identify the maximum proportion of affordable housing that can be delivered viably without public subsidy; and

- Ensure proposals in the City Centre provide affordable housing through a threshold approach; and

- Where 35% cannot be delivered without public subsidy agree to work with the council to deliver the shortfall through other mechanisms; and

- Where 35% can be delivered without public subsidy agree to work with the council to explore ways to increase the delivery of affordable housing above this percentage.

Where developers consider that scheme viability may be affected by the policy's requirements, they will be expected to demonstrate whether particular circumstances justify the need for a viability assessment and provide full development appraisals to demonstrate an alternative affordable housing provision.

Affordable housing tenure proportion

Affordable housing secured without public subsidy should normally be provided as 75% social rent and 25% affordable home ownership which can include First Homes.

General provisions

In all cases proposals should ensure that:

- Affordable housing provision is met on site unless off-site provision or an appropriate financial contribution in lieu can be robustly justified and the agreed approach contributes to the creation of mixed and balanced communities;

- Affordable housing provided is transferred to one of the council's HomesWest registered provider partners, the council as a social landlord, or to any other affordable housing partner as agreed with the council (with the exception of Affordable Private Rent and First Homes);

- Affordable housing is made available to eligible and qualifying households at a locally affordable price;

- Affordable housing for rent and shared ownership and First Homes continues to remain at an affordable price for future eligible households or, if this restriction is lifted, for the subsidy to be recycled for alternative affordable housing provision.

The council's Affordable Housing Practice Note provides guidance on the implementation of this policy.

The proposed policy has a very different approach to secure affordable dwellings in the City. There are a variety of delivery mechanisms that can be used to ensure that the minimum percentage requirement is met.

This policy starts at 10+ dwellings rather than splitting up into different thresholds in the adopted policy. At least 35% affordable housing will be sought on residential developments of 10 units or more and developers will be expected to identify the maximum amount that can be delivered viably.

If 35% cannot be delivered without public subsidy, the developer is expected to work with the Council to deliver the difference through other mechanisms. However, if the 35% can be met without any public subsidy, the developer is then expected to work with the Council to increase the percentage of affordable housing provided through the other delivery mechanisms.

However, viability can be looked at in the planning stage and demonstrated through an FVA.

The proposed tenure mix would be as below:

75% = Social Rent

25%= Affordable Home Ownership (can  include First Homes)

The preferred provision for all of the above is on-site; however, if it can be robustly justified, an off-site provision or financial contribution in lieu may be considered.

Main Differences

The main changes are summarised below:

S106 Management would recommend a site-specific viability assessment on all developments of 10+ dwellings should the proposed policy be accepted as above.

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September 28, 2023

South Holland Affordable Housing Policy

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Three Rivers Affordable Housing Policy

Three Rivers seeks 45% affordable housing across the Borough, can your development sustain such high targets and still be viable?
Proposals to 'scrap s106 developer contributions' and new flat-rate ‘Consolidated Infrastructure Levy’
April 19, 2022

Proposals to 'scrap s106 developer contributions' and new flat-rate ‘Consolidated Infrastructure Levy’

S106M comment on reports suggesting the government's proposals to scrap section 106 developer contributions, affordable housing policies and CIL and replace them with a 'Consolidated Infrastructure Levy' will be included the Queen's Speech and come forward for consultation shortly. We outline the potential challenges and propose a constructive solution.

High Section 106 costs are avoidable

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