A key proposal, contained with Paragraph 71 of the revised NPPF was published in July 2018 is the introduction of Entry Level Exception Sites. Looks to me like a good idea that could be loaded with some painful unintended consequences.
These are sites that provide entry-level homes suitable for first-time buyers (or equivalent, for those looking to rent). There must be an identified lack of entry-level housing, and development must be:
- suitable for first-time buyers
- on land not allocated for housing
- adjacent to existing settlements and no larger than 1 ha in size or not exceed 5% of the size of the existing settlement
- in compliance with local design policies and standards
- made up of entry-level homes that offer one or more types of affordable housing
- outside National Parks, AONB’s or the Green Belt.
- Entry Level Exception Sites do not fall within the general definition of affordable housing within the glossary of the NPPF, and have their own definition which allows for individual consideration on appropriate sites.
So what are the significant differences to the usual format of ‘rural exception sites’?
- The occupation isn’t restricted to current village residents, or those with a local family or employment connection, thus opening sites to a wider market.
- Planning permission won’t be dependent on their being a specific local need for affordable housing.
- Paragraph 71 of the NPPF does not require that the land involved must be used for affordable housing ‘in perpetuity’. So theoretically there could be a future change to market housing.
- Maximum site size is given in the NPPF.
What are the unintended consequences that I’m worrying about?
- Entry Level Exception sites may be more profitable to develop than the usual form of rural exception sites, and easier for local landowners and developers to fund and bring forward themselves. This could lead to a greater frequency and quantity of ‘exceptions ‘ and a lot more unexpected development on land around our smaller towns, villages and hamlets.
- Because Entry Level Exception Developments may be more easily done ‘in house’ and not involve a housing association, lack of local design expertise could led to more sub-standard developments (and to a lesser degree, some welcome innovation in design).
- LPAs and Housing Associations may find that the supply of land for traditional affordable housing exceptions reduces, harming one of their key planning tools for the delivery of affordable housing in rural areas.
- The specification of maximum site sizes could lead developers to seek permissions that comply closely to the guidance, leading to excessively large estates for some locations, or creating estates with a limited housing mix that is more likely to fail socially.
There are also ways that the Entry Level and Rural Exception sites are identical: for example in being essentially a form of ‘un-planning’ that may never deliver and when it does almost always has the consequence of seriously aggravating local residents, creating vigorous protest and ultimately discrediting of the planning system and profession. (Yes, I don’t like the concept!).
I reckon all this strongly reiterates the need for NDPs to include strong policies to control the exception sites that NPPF and Local Plans encourage and enable. These could for example identify areas where, for well justified reasons, exception sites will not be welcomed, or include locally based criteria about the scale, form, and layout etc, or require adherence to a well researched local design code.
Of course the only real and effective answer is for NDP qualifying bodies to stand up and be brave enough to allocate a few sites to ensure that at least some affordable housing is guaranteed for their local youngsters and others, on sites that the local community have had the opportunity to evaluate, discuss and ultimately agree to through the NDP referendum.