There exist a number of risks and opportunities for affordable rural housing at present. These include the introduction of First Homes Exception Sites, the thresholds at which sites are required to provide affordable homes and the proposals put forward in the Planning White Paper. All have the potential to disrupt the supply of affordable rural homes, destroy community trust in the process and undermine the sustainability of rural communities.

1. The proposed introduction of First Homes Exception Sites will disrupt the supply of genuinely affordable rural homes. They will increase land values and stymie the flow of traditional Rural Exception Sites. The existing programme of delivery will diminish as landowners and communities pause opportunities. Critically, the level of homes being built will fall just as the ambition is to build more of them. The rural exemption for this proposal is wholly inadequate and evidences the absence of rural proofing.

Solution: Exempt parishes with populations of 3k or fewer and all parishes in National Parks and AONBs.

2. The proposal to increase the threshold at which market sites are required to provide onsite affordable homes to 40, even for a temporary period of 18 months, will destroy community trust in the planning system and devastate the supply of affordable rural homes. Without a change to the definition of rural areas there is a danger that in 70% of parishes with a population of 3k or fewer there will be no opportunities for these communities to meet their housing needs.

Solution: Exempt parishes with populations of 3k or fewer and all parishes in National Parks and AONBs and retain a threshold of 10 for settlements between 3k to 10k.

3. As drafted, the proposals in the Planning White Paper could undermine sustainability of rural communities, in particular ‘protected area’ zoning could preclude communities in these areas from the growth necessary for them to be sustainable and the Infrastructure Levy could result in affordable housing not being provided, a particular risk in rural areas if too high a development size threshold is set for charging the level.

Solution: Current criteria used to make sustainability assessments are no longer fit for the modern, digital age and should be re-examined. Local authorities should take greater account of access to services such as broadband which provides vital connections to other services and amenities which reflect 21st century living. Local planning authorities should be required to conduct housing needs assessments in those communities not allocated housing in Local Plans.

1. A focus on delivering genuinely affordable homes supports the Governments ‘levelling-up’ ambition. The 10% rural target in the Affordable Homes Programme is welcomed because of this. Supported by a positive planning and housing policy framework there is more that can be achieved by delivering affordable rural homes to support national prosperity and well-being. Amending the AHP target to 10% of investment would show an even stronger commitment to supporting affordable rural housing delivery and levelling-up rural communities.
   
   
2. Working with Homes England, the potential for more strategic rural delivery through key rural housing association partners could be explored. This could include targeting support to releasing capacity from smaller housing associations. The approach could secure greater efficiency, scale and impact. The Rural Housing Alliance would be well placed to explore this further with Homes England and MHCLG.
   
   
3. Allowing local determination of affordable rents based on agreed parameters (e.g. percentile of local earnings) would enable greater flexibility for public grant rates. The current approach of having affordable and social rents offers little to no discretion of Homes England investment staff or housing association viability modelling.