Affordable Homes in New Development
Introduction
The Affordable Homes in New Development Supplementary Planning Document (SPD), published in March 2025 by Hart District Council, provides comprehensive guidance on delivering affordable homes through the planning system. This document supports Policy H2 (Affordable Housing) of the Hart Local Plan (Strategy & Sites) 2032 (HLP32). It is a material consideration in determining planning applications, meaning decision-makers must take it seriously when assessing new housing proposals.
The SPD emphasizes that affordable housing must be considered early in the planning process. This early engagement ensures the optimum quantity, tenure, and mix of affordable homes that meet genuine local needs. The Council offers a pre-application advice service to help applicants identify and overcome potential issues before submitting a planning application, speeding up the overall process.
The document is designed to help applicants interpret and meet national and local planning policy requirements regarding affordable homes. If viability is a concern, the Council’s associated Viability Appraisals for New Development SPD (2023) should also be consulted. The SPD does not specifically address rural exception sites (Policy H3), but much of the guidance applies to those schemes as well.
Background and Corporate Priorities
Delivering mixed and balanced communities is a key element of good planning. The provision of new homes, including well-integrated affordable homes, promotes healthy and safe communities. Affordable homes are defined as those for people whose needs are not met by the market, including various products for rent or ownership. The full definition is set out in Annex 2 of the National Planning Policy Framework (NPPF).
The Council’s Corporate Plan (2023–2027) focuses on three areas: Planet, People, and Place. Under “Place,” a priority is “delivering warmer, better homes in sustainable locations that people can afford to live in.” The Plan highlights that access to safe, secure, and affordable housing is fundamental to wellbeing and sustainable communities. One specific goal is to “provide more social rented homes, and more affordable market rented homes for local people and our key workers.”
The Hart District Council Housing Strategy 2020-2025 reinforces this commitment, aiming to maximise delivery of high-quality, suitable, and affordable new homes throughout the district. Key actions include negotiating delivery of 40% affordable homes on all eligible sites where viability is proven, and working with housing providers and planners to deliver an appropriate mix based on evidence of housing need (including the Strategic Housing Market Assessment and Hart’s Housing Register).
Additionally, the Council declared a climate emergency in April 2021, pledging to make the district carbon neutral by 2040. Significant weight is given to this declaration in all planning decisions.
National and Local Planning Policy Context
The National Planning Policy Framework (NPPF) December 2024 (note: the document references both 2023 and 2024/2025 versions; the SPD is March 2025) aims to significantly boost housing supply and address local housing needs. Local authorities must establish the size, type, and tenure of housing needed, including for those requiring affordable housing. The NPPF elevates the importance of Social Rent as a tenure, requiring local planning policies to specify the minimum proportion of Social Rent homes required. The default position is that affordable homes should be provided on-site unless off-site provision or a financial contribution can be robustly justified.
The Hart Local Plan (Strategy & Sites) 2032 (HLP32) was adopted in April 2020. Policy H2 sets out requirements for affordable homes in new development. Applicants should also be aware of other policies on housing mix (Policy H1) and rural exception sites (Policy H3). Neighbourhood plans may include their own requirements, and applicants should have regard to other supplementary guidance, including Technical Advice Notes on viability, parking, and biodiversity.
When Policy H2 Applies (Thresholds)
Policy H2 applies to major developments providing homes in Use Class C3 (dwelling houses) where 10 or more homes are proposed, or the site area is 0.5 hectares or more. Use Class C3 includes self-contained accommodation for day-to-day living, including extra care housing, sheltered housing, and retirement homes.
The 10-dwelling threshold refers to the gross number of homes proposed. The 0.5-hectare threshold refers to the gross area within the red line on submitted plans. Crucially, the policy states that developments which artificially restrict the site area or level of development to avoid providing affordable housing will be refused.
Where sites are sub-divided, the Council expects each subdivision to contribute proportionally toward the affordable housing that would have been required for the whole site. Sites in the same ownership or with a clear physical relationship (even different ownerships) will be treated as one planning unit. The Council will consider whether ancillary land (gardens, open space, parking) has been excluded from the red line. Any existing home or building on a plot will only be excluded if there is no material alteration to it.
Efficient Use of Land
Proposals that do not make efficient use of land for example, unusually large homes that keep the dwelling count below 10 will be refused if the Council considers the land could be used more efficiently. Factors considered include:
Density of the proposed development
Mix of home sizes (bedrooms) compared to the HLP32 starting point: 7% 1-bed, 28% 2-bed, 44% 3-bed, 21% 4-bed
Sizes compared to the Nationally Described Space Standards (NDSS) 2015
Whether the proposed gross internal floor area (GIFA) exceeds the floorspace required for 10 homes using average minimum GIAs (derived in Appendix 1): 48m² for 1-bed, 70m² for 2-bed, 91m² for 3-bed, 110m² for 4-bed
The Council also considers local character and context, but low-density context does not automatically rule out higher density.
Amount and Tenure Mix of Affordable Homes
To deliver mixed communities and respond to local need, Policy H2 requires 40% of new homes on qualifying sites to be affordable homes. This 40% must be provided in accordance with criteria a) to g) of the policy. Proposals failing to meet this will only be granted when fully justified.
Of the 40% affordable housing provided:
65% must be affordable homes for rent
35% must be affordable home ownership (e.g., shared ownership)
The SPD clarifies that the 65% affordable homes for rent are required to be provided as Social Rented homes, not Affordable Rent. This is based on an AECOM study (October 2024) which found that 51–57% of households on Hart’s Housing Register cannot afford Affordable Rent (even at 40% of income on rent). These households need Social Rent.
If providing 65% Social Rent is not financially viable, the applicant must submit an open book viability assessment. The Council will commission an independent expert review, paid for by the applicant. A separate viability study (Three Dragons, September 2024) indicates that meeting the 65% rent element entirely with Social Rented homes is generally viable, except potentially on some brownfield sites requiring Thames Basin Heaths Special Protection Area mitigation (SANG and SAMM). Even on those sites, existing use values vary, and Vacant Building Credit may apply.
Therefore, the starting point for all sites across the district is to provide the 65% rented element as Social Rent. This must be made clear to landowners and developers when considering land value. The mix of affordable homes should be discussed with the Council’s Development Management Case Officer and Housing Strategy & Development Team to obtain the latest needs information.
Vacant Building Credit
If Vacant Building Credit (VBC) applies, the affordable housing contribution is reduced proportionately. VBC applies to vacant buildings (not abandoned buildings) on brownfield sites. A building is not vacant if it has been in continuous use for any six months during the last three years. The applicant must provide a Vacant Building Credit Statement with evidence of vacancy, floor areas (GIFA), and that the building is not abandoned. The Council determines on a case-by-case basis. At outline stage, the matter can be deferred via a Section 106 agreement.
Distribution of Affordable Homes (Tenure Blind)
Affordable homes must be provided on-site, interspersed and distributed throughout the development mixed with market housing (Policy H2 criterion a). Large concentrations of affordable homes must be avoided. Small clusters are appropriate, but rented homes should be in small groups, and shared ownership homes in separate small groups. Small terraces and pairs of semi-detached properties should be the same tenure. Blocks of flats should consist of one tenure only (just rented or just shared ownership), with a maximum of 12–15 flats per block, well distributed across the site.
On larger phased sites, affordable housing should achieve 40% across the whole site, with each phase having a minimum of 25% and maximum of 50% affordable homes. Concentrations across adjoining phases must be avoided.
Affordable homes should be “tenure blind” indistinguishable from market homes in design, form, external appearance, and materials.
Property Types and Sizes
The types of affordable homes should reflect the market homes on the site (e.g., predominantly houses, not flats). The most acute need is for Social Rented 3-bedroom and 4-bedroom houses. These should form part of the mix on suitable sites, especially where 3-bed and 4-bed market houses are proposed. Affordable homes should be houses (semi-detached or small terraces) rather than flats, unless the site is better suited to flats. Three-bedroom or larger affordable homes must be houses (family homes need private garden space).
Where flats are acceptable, a mix of 1 and 2-bed units is considered, but 1-bed flats in a block of 2-bed units should be designed to minimise anti-social behaviour risks. Applicants proposing flats as affordable homes should speak to a Registered Provider and use pre-application advice to ensure acceptability. The Council wants to avoid granting permission for flatted affordable homes that no Registered Provider will take on.
Affordable homes should not be detached (unless for specific needs like accessible housing) and should not have garages, car barns, or en-suite bathrooms to retain affordability.
Occupancy Levels, Internal Layout, and Space Standards
Maximum occupancy levels for affordable homes should be:
1-bed: 2 persons
2-bed: 4 persons
3-bed: 5 or 6 persons
4-bed: 6, 7, or 8 persons
New homes, including affordable homes, must meet Nationally Described Space Standards as a minimum (Policy H6). Internal layout should avoid noise disturbance: high-noise areas (kitchens, living rooms) should not adjoin low-noise areas (bedrooms) in neighbouring attached properties or flats. In 2+ bedroom homes with open plan living, layouts should allow child safety gates to separate the kitchen from living spaces. Bedrooms should be positioned to avoid noise from within or outside the home.
Outdoor Space and Healthy Living
Private gardens must be provided for residents of all houses. For flat occupiers, outdoor amenity space should be provided, with private gardens where possible (especially for maisonettes and small blocks). Where gardens are not possible, usable balconies or well-designed landscaped areas are required. The Public Health Authority and the Building for a Healthy Life Design Toolkit (2020) highlight strong evidence linking usable outdoor space to mental and physical health, particularly evident during the COVID-19 pandemic.
Accessible and Adaptable Homes
Policy H2 requires that 15% of all affordable homes must be accessible and adaptable as defined by Building Regulations Part M4(2). Part M4(2) is encouraged for all new affordable homes. Where local need is evidenced, some affordable homes should be built as wheelchair user homes to meet or exceed Part M4(3). These requirements should be discussed early with the Housing Strategy and Development Team. The Council liaises with an independent housing occupational therapist to address specific household needs.
Specialist or Supported Housing
Policy H2 applies to all residential development in Use Class C3, including private retirement homes, sheltered accommodation, and extra care schemes. For specialist or supported housing, applicants should engage early to establish whether on-site or off-site affordable housing is appropriate, or a financial contribution. As much affordable housing as is viable (up to 40%) will be sought on a site-by-site basis, informed by a viability assessment. The Council may take a more flexible approach on size, mix, and occupancy for schemes like Extra Care, using best practice from HAPPI (Housing our Ageing Population Panel for Innovation) design principles.
Part-Dwelling Payments and Off-Site Provision
Mathematically, the 40% requirement often results in a fraction of a dwelling. The Council will calculate a financial contribution equivalent to that part-dwelling using its Affordable Housing Financial Contribution calculator.
Off-site provision or a financial contribution in lieu of on-site affordable homes is only accepted where robustly justified and on-site provision is impractical. This is consistent with NPPF 2023 paragraph 64 and HLP32 paragraph 144. The Council considers this on a site-by-site basis in exceptional circumstances. Any off-site provision must be completed before or alongside the market homes, or a financial contribution paid on first occupation.
The Planning Application Process
The Council strongly advises pre-application advice for any proposal where Policy H2 applies. This reduces the risk of refusal due to affordable housing issues. Applicants can request specialist advice from the Housing Strategy and Development Team (fee applies). The Council’s protocol is positive and proactive, but unsatisfactory applications may be refused without discussion if they are unacceptable in principle, ignore clear pre-application advice, or no advice was sought.
Applicants should prepare and submit with their pre-application request:
Site plan showing location and distribution of affordable homes (size and tenure)
Accommodation schedule (phase, plot, bedrooms, m², max occupancy, floor level, property type, tenure, parking, accessibility)
Phasing and timing details
Validation requirements for a planning application include an Affordable Housing Statement with: numbers of affordable homes, accommodation schedule (tenure, bedrooms, m², plot numbers, type), plans showing location and habitable rooms/bedrooms/floor space, and details of any Registered Provider. The Council also requests at pre-application stage: occupancy levels, rent type (social rent or affordable rent), accessibility standards (M4(2)/M4(3)), and car/cycle parking provision.
Content of Section 106 Legal Agreement
A Section 106 agreement secures and controls the provision and delivery of affordable homes. It typically covers:
Description of affordable/specialist homes (bedrooms, type, tenure mix)
Location of affordable homes within the site
Phasing to ensure affordable homes are developed at an agreed rate relative to market housing
Transfer to a Registered Provider at an agreed price
Allocation of rented homes through the Council’s housing register
Rent type (Affordable Rent or Social Rent)
Discount levels for discounted market homes
Perpetual affordability (including Designated Protected Area restrictions)
Financial contribution mechanism for off-site provision
Staircasing recycling arrangements
Mortgagee in Possession clause
Property Management, Allocations, and Affordability
The Council expects affordable homes to be owned and managed by a Registered Provider (RP) from the Council’s list of preferred partners. A Nomination Agreement must give the Council the right to nominate 100% of homes on first let. Subsequent lets follow the Nomination Agreement.
Registered Providers must have regard to the Council’s Tenancy Strategy 2023-28. Social rents are set according to Government policy (typically 60–65% of open market rent). Affordable Rent levels for 1, 2, and 3-bed properties should be no more than the maximum Local Housing Allowance (LHA) rate for the Broad Rental Market Area (Blackwater Valley, Basingstoke, or Reading). For 4-bed properties, caps are 64% (Blackwater Valley), 78% (Basingstoke), or 66% (Reading) of LHA. Service charges must be kept to a minimum.
Appendix 1 – Average Minimum Gross Internal Floor Area
This appendix explains how the average minimum GIAs (48, 70, 91, 110 m²) were derived from the Nationally Described Space Standards, averaging the smallest and largest minimum GIA for each bedroom number, accounting for variations in bed spaces and storeys.
Appendix 2 – Vacant Building Credit (detailed)
Detailed guidance on VBC: the entire building must be vacant (not partially occupied). A building is not vacant if used for any six months in the last three years. Abandoned buildings do not qualify. The applicant must prove vacancy, condition, time out of use, other uses, and owner’s intentions. GIFA is measured to RICS definition. At outline stage, the matter is deferred via S106. The building should not be demolished until replacement homes are approved.
Glossary
The SPD includes a full glossary defining key terms: Affordable housing, Social Rent, Affordable Rent, Discounted market sales housing, Shared ownership, Build to Rent, Designated Protected Area (DPA) , Housing Strategy, Local Plan, NPPF, Neighbourhood Plan, Nomination agreement, Planning obligation, PPG, Preferred Partner Registered Provider, Registered Provider (RP) , Section 106 agreement, and more.
Conclusion
This March 2025 SPD is essential reading for developers, landowners, and planning agents operating in Hart District. It sets a clear, evidence-based, and ambitious standard for affordable homes in new developments, prioritising Social Rent and requiring 40% affordable housing on qualifying sites. Early engagement, tenure-blind design, appropriate distribution, and robust legal agreements are key to successful planning applications. The document balances local housing need with viability considerations, making it a model for contemporary affordable housing policy implementation.
Also Read: Affordable Housing Finance &Amp; Overview Of State Programs