Affordable Housing Topic Paper
Introduction
The Telford & Wrekin Council has published its Affordable Housing Topic Paper as part of the evidence base supporting the emerging Local Plan 2021–2041, submitted for examination in September 2025. This document provides the justification behind two key planning policies: Policy HO4 (Affordable Housing Requirement) and Policy HO5 (Affordable Housing Delivery). The purpose of the paper is to demonstrate that the proposed affordable housing targets are evidence-based, viable, and consistent with national planning policy, particularly the National Planning Policy Framework (NPPF) published in December 2024.
The paper draws on several core evidence sources, including the Economic and Housing Development Needs Assessment (EHDNA) Update (February 2025), the Whole Plan Viability Assessment (WPVA) June 2023, and the WPVA Update Note (December 2024). These documents collectively inform the council’s approach to setting affordable housing requirements, tenure mixes, and delivery mechanisms across the borough.
National Planning Policy Context
The topic paper begins by aligning the proposed policies with the NPPF 2024. Under national policy, strategic policies must make sufficient provision for affordable housing. The NPPF defines affordable housing to include Social Rent, Other Affordable Housing for Rent (including Affordable Private Rent in Build to Rent schemes), Discounted Market Sales Housing (minimum 20% below local market value), and Other Affordable Routes to Home Ownership (such as shared ownership and rent to buy).
Crucially, the NPPF requires local planning authorities to specify the type, size, and tenure of affordable housing needed. Paragraph 64 of the NPPF states that affordable housing should be met on-site unless off-site provision or financial contributions in lieu can be robustly justified. The government’s Written Ministerial Statement (May 2021) removed the previous minimum 25% requirement for First Homes, giving councils greater flexibility.
The paper also notes that viability remains a key consideration: policies should set out expected contributions, including affordable housing provision, without undermining the deliverability of the plan.
Affordable Housing Need Evidence
The EHDNA Update (February 2025) forms the backbone of the need assessment. It identifies 1,208 households currently in need across Telford & Wrekin, comprising 416 homeless households, 90 lettings to reasonable preference categories, 438 overcrowded households, and 264 concealed households.
When newly forming households unable to afford lower quartile rents (787 per year) are added to existing households falling into need (338 per year), the gross annual need rises to 1,125 households per year. After accounting for supply, the net affordable housing need is calculated at 824 affordable homes per year over the plan period to 2041.
Need for Social and Affordable Rented Housing
The EHDNA finds that 47% of households cannot afford market rent. The total newly arising affordable housing need is 1,125 dwellings per annum (dpa). Against this, the annual supply is insufficient, leading to a substantial requirement for social and affordable rented housing. The assessment concludes that 696 social and affordable rented units per year are needed across the borough.
Where practicable, the evidence recommends a tenure split of 66% social rent and 34% affordable rent. However, the paper acknowledges that the final split must be reconciled with viability, site-specific circumstances, and national guidance.
Need for Affordable Home Ownership Products
For affordable home ownership, the EHDNA estimates that to purchase an entry-level property at £160,000, a household requires an income of £38,860 (assuming a 3.5 loan-to-income ratio and 15% deposit). The current backlog combined with newly forming households unable to buy on the open market generates a need for 128 affordable home ownership properties per year. This includes shared ownership, discounted market sales, and other low-cost home ownership products.
Past Trends in Affordable Housing Delivery
The paper reviews the council’s track record using Annual Monitoring Report (AMR) data from 2013/14 to 2023/24. Over the last ten years, 25% of all housing completions in Telford & Wrekin have been affordable dwellings. In the most recent five years, the average is 28%. This strong delivery record is attributed to proactive working with Homes England, registered providers, and developers.
Historical policies (HO5 and HO6 from the adopted 2011–2031 Local Plan) required 25% affordable housing in the Telford built-up area and 35% in Newport and the rural area the same percentages now proposed in the emerging Policy HO4. Delivery dipped slightly in 2020 due to the Covid-19 pandemic but has since recovered.
Tenure Mix Delivered
Between 2017/18 and 2023/24, the majority of affordable housing delivered has been affordable rent, with social rent forming the smallest proportion. Over the seven-year period, affordable rent accounted for approximately 20% of total affordable completions, intermediate/shared ownership 12%, and social rent just 9% (in certain years). This under-delivery of social rent aligns with the EHDNA’s recommendation to prioritise social rent moving forward.
The council also highlights successful schemes delivered through a 10-year Land Deal with Homes England, which has generated over £60 million in gross sales income and facilitated 25 residential sites. Since 2011, an average of 310 affordable dwellings per year have been transferred to registered providers.
Viability Evidence
The Whole Plan Viability Assessment (WPVA) 2023 and 2024 update tested various affordable housing thresholds (from 0% to 40%) across 30 typologies, including greenfield and brownfield sites, different scales, and build costs. The WPVA found that average house prices in Telford & Wrekin (£237,295) remain below national averages (£303,769), although newbuild prices rose by 20% (approx. £58,000) between April 2023 and September 2024.
The WPVA (2024) recommended a target of 20% affordable housing in Telford and 35% elsewhere. However, the council has chosen to set Policy HO4 at 25% in Telford and 35% in Newport and the rural area for several key reasons:
Unmet need: The EHDNA shows a requirement for 824 affordable homes per year, far exceeding what even a 35% policy could deliver. A higher target helps maximise delivery.
Grant funding excluded from WPVA: The viability assessment did not account for Homes England grant funding, which has historically supported around 60% of affordable housing delivery in the borough. Many brownfield sites are in public ownership, and gap funding is routinely secured.
Strong track record: The council has consistently achieved policy-compliant affordable housing delivery, often exceeding the viability modelling’s conservative assumptions.
The paper therefore modifies Policy HO4 to explicitly state that developers must demonstrate they have investigated other sources of supply, including Homes England grant, to meet the required percentages. The council argues that this approach is both viable and justified.
Setting the Affordable Housing Requirement: Policy HO4 and HO5
Policy HO4 – Affordable Housing Requirements
The emerging Policy HO4 requires all major residential developments to deliver a minimum of:
25% affordable homes in the Telford built-up area
35% affordable homes in Newport and the rural area
The council will secure a tenure mix covering both affordable rent and affordable home ownership, informed by government guidance and local need. Developments delivering up to 100% affordable housing are supported where they meet local needs and create mixed communities. Where developments fail to meet the policy requirements, a viability assessment must provide clear justification.
The paper justifies the higher percentage in Newport and rural areas on the basis that these areas are less affordable and have a lower existing stock of affordable housing compared to Telford.
Policy HO5 – Affordable Housing Delivery
Policy HO5 sets out how affordable housing will be delivered. The majority is expected on-site, but off-site contributions (at a minimum of 10% of the proportion set out in Policy HO4) will be required where:
It helps meet housing needs for specific groups (e.g., care leavers, homeless, older people, Gypsy and Traveller community)
On-site delivery is not feasible or practical
There are overriding benefits to off-site provision
The policy prioritises affordable housing for rent and requires that affordable homes be tenure-neutral in design, materials, space standards, and parking. Off-site financial contributions will be used to deliver specialist and supported housing, bring empty homes back into use, and provide temporary accommodation for homeless households.
Examples of successful schemes include:
Octavia Court: Refurbished to create 11 supported living units for young care leavers
Lion House: Redeveloped derelict pub into 11 social rent units for adults with learning disabilities
Maurice Lee Avenue: Converted empty semi-detached houses into 8 units of social rent and temporary accommodation
Lakewood Court: Former residential home converted into 16 supported living units
Farcroft: Redeveloped former care home into 27 units for high-needs dementia care
The council has directly invested in these projects, leveraging additional Homes England grant funding.
Unmet Needs and Specialist Accommodation
The paper identifies several specific affordable housing needs that are not met through general needs developments. These include:
Fully accessible and adapted supported accommodation for acquired brain injury, physical disabilities (adults and children), and bariatric needs
Supported accommodation for care leavers and vulnerable young people transitioning to independent living
High-needs extra care schemes for older persons and dementia care
Properties reserved for veterans or care leavers let at social rent
General needs property types that the market undersupplies, such as 1-bed houses, 1-bed apartments, 4-bed, 5-bed, and 5+ bed houses, and fully accessible homes of all sizes
The council will adopt a “worst first” strategy to bring empty homes back into use, prioritising properties in the most pressing condition.
Conclusion: Justification and Effectiveness
The topic paper concludes that Policy HO4 and Policy HO5 are justified, effective, and fully compliant with national planning policy. The key justifications are:
Robust need evidence: The EHDNA (2025) demonstrates a clear requirement for 824 affordable homes per year, with the greatest need for social and affordable rented accommodation (696 dpa).
Strong delivery track record: Historically, 25-28% of completions have been affordable, supported by Homes England grant and proactive council intervention.
Viability reassessed: Although the WPVA recommended lower targets in Telford (20%), the council has reasonably set a 25% target because the viability work excluded grant funding. Including grant makes 25% deliverable.
Policy modification: The addition of a requirement to investigate grant funding (Policy HO4, part 5) provides clarity and ensures developers exhaust all options before seeking reduced contributions.
Targeted off-site contributions: Policy HO5 allows financial contributions to be pooled and deployed for specialist and supported housing, addressing needs that standard on-site provision cannot meet.
The paper also acknowledges that even with these targets, the affordable housing need (824 dpa) significantly exceeds the projected supply from major developments. This is not uncommon in Local Plans, but the council argues that maximising delivery through higher percentages, grant funding, and off-site contributions is the most effective response.
Final Thoughts
This Affordable Housing Topic Paper serves as a model of evidence-led policy making. By integrating housing need data, past delivery trends, viability testing, and practical delivery mechanisms, Telford & Wrekin Council has constructed a defensible and ambitious affordable housing framework. The 25% (Telford) and 35% (Newport/rural) targets are set to maximise affordable housing delivery, while the flexible approach to tenure mixes and off-site contributions ensures that even the most specialist local needs can be met.
For developers, registered providers, and communities, the message is clear: affordable housing is a priority, and the council expects developments to contribute proportionately, transparently, and creatively including through the use of Homes England grant funding to address the borough’s significant and growing need for homes that people on lower incomes can actually afford.
Also Read: 14th Annual Demographia International Housing Affordability Survey: 2018