Rural exceptions: no longer the rule

The government surprised most of us with the proposed changes to planning policy guidance note PPG3 just before the summer recess. Fortunately, we have until 31 October to make representations.

Perhaps the most significant proposal concerns the rural exceptions policy. Dating back to 1988, the policy – the first attempt to deliver affordable housing via the planning system – is now up for abolition. Currently, it is enshrined in planning guidance documents PPG3 and Circular 6/98.

The former states that in rural areas, the normal process of negotiating affordable housing on development areas above the site size threshold may be "augmented" by granting planning permission for "land within or adjoining existing villages", which would not usually be released for development, in order to provide affordable housing to meet local needs. The circular says that such policies may be appropriate within and adjoining villages that are subject to restraint, such as green belt. It also explains that it is inappropriate for development plans to identify particular exceptions sites and allocate them for affordable housing.

Under the proposals, the relevant guidance is to be replaced by a single paragraph. The last two sentences read: "Provision in rural areas may also be supported by allocating sites solely for affordable housing, on land within or adjoining existing villages, which would not otherwise be released for housing … [Where] this would contribute to the attainment of mixed communities … affordable housing provision should meet local needs."

There is therefore a very clear distinction between the current and the proposed policy. The intention is that in the future, sites must be specifically identified through the development plan process before planning permission is granted. The present system, on the other hand, is based on the development plan containing criteria-based policies, against which ad hoc individual planning applications can be judged.

Furthermore, under the proposed changes, rural affordable housing allocations will count towards the overall requirements fixed by regional planning guidance and structure plans: under the present system, rural exceptions provision is additional.

The policy has not been an overwhelming success. The numbers of dwellings produced has been modest compared to the affordable housing crisis. Many planning authorities have been reluctant, and in several areas it has required the appointment of special rural housing enablers to make it work. Indeed, the planning profession appears ideologically opposed to the concept of making "exceptions" in "unsustainable" locations.

Will the changes deliver more affordable housing in rural areas? The answer can only be an emphatic ‘no’

The present system does, however, make a significant contribution in some localities. It allows land availability from benevolent landowners, unfulfilled requirements arising from local parish housing needs surveys, Housing Corporation funding and local goodwill to be melded in a pragmatic manner. The best site in the village is often not available at the right time and cannot always be identified in advance. The process of earmarking sites in local plans will surely cause delay in itself, adding "hope value" that will lead landowners to hold on to land and encouraging potential objections. On what basis will planners make allocations? District-wide housing needs assessments lack the necessary detail for priorities to be made properly on the basis of need.

The principal weakness in the current provision warranting attention is the statement in annex B that "general market housing, or mixed developments consisting of high-value housing used to cross-subsidise affordable housing on the same site, are inappropriate on exception sites". In response to this, the Countryside Agency developed the concept of "sites for social diversity", representing a hybrid between the housing allocation and rural exceptions approaches. The proposed changes remove the prohibition but do nothing to enable such innovation.

An indirect consequence of the wider provisions of PPG3 has been a reduction in overall housing allocations in rural areas, on account of the sequential approach and issues of locational sustainability. Therefore, opportunities to negotiate affordable housing from developers are diminishing. The rural white paper of November 2000 sought to address this, at least partially, by stating that there "is no reason why in small villages … every new market house should not be matched by an affordable home".

This wording isn't in the proposed changes, which merely point to the potential contribution of "small sites", defined as those under 0.5 ha or including developments of less than 15 dwellings.

This is hardly the same.

Will the changes deliver more affordable housing in rural areas? The answer can only be an emphatic "no". The best solution would be to keep the exceptions approach, alongside a provision for allocating sites for "up to" 100% affordable housing.