Please join us in responding to the National Planning Policy Framework Consultation – Closing date – 23 September 2024

Dear Members

Thank you so much for all your support with the amendment to the National Planning Policy Framework (NPPF) so far. Your support has already helped significantly. As you may know there is now a consultation on the NPPF and the attached paper sets out the response of The Almshouse Association. We need your help again to help push this over the line. This consultation closes on the 23 September 2024 so we are throwing our full efforts behind; it may be our best chance.

Can you spare a few moments to add your voice to the consultation? It really will only take a few moments, and I think this is possibly our best chance at seeing change. It would be great if you could.

Please log onto: Proposed reforms to the National Planning Policy Framework and other changes to the planning system – Page 1 of 19 – Ministry of Housing, Communities and Local Government – Citizen Space

  1. Complete your charity details.
  1. There are over 100 questions in the online consultation. The Almshouse Association feels our remit allows us to answer further questions related to affordable housing and planning and our answers can be found in our written response paper here. As independent charities, you will decide on your responses to any questions that you feel relevant, however if you are short of time and can only answer one or two questions, can we ask that those questions are the most important for us all –  Questions 56 and 57  – which have been drafted by Government directly seeking a response from the almshouse network. You will need to read the questions in more detail for context and I have copied the questions in the adjoining written response paper (see link above), however for ease, our responses to Qs 56 and 57 are set out below.

    Please adapt as you see fit. We have underlined and highlighted in BOLD the amendments we would like to see to the wording of the current NPPF definition of affordable housing, however the key message we are hoping to raise is that almshouse charities that are not Registered should be considered able to apply for Section 106 benefits, in the NPPF definition of affordable housing.
  1. It would also be a great help if you are also able to send the enclosed letter to your local MP having made the appropriate amendments.

TAA Responses to the consultation – Qs 56 &57:

The full background and context to the questions can be found in the written response paper (see link above) and in the consultation document online.

Question 56 – Do you agree with these changes?

Answer 56: – Almshouse charities are often the only form of affordable housing in rural areas. Trustees are drawn from the community. Almshouses are exempt from the Right to Buy and the homes are offered in the community, led by those from the community in perpetuity. Almshouses are community housing in all but name. The definition for community housing should include almshouses as charities. Charities are restricted to work on the terms of their Governing Documents by law and it is essential that the definition of “Community Led Housing” does not exclude charities that deliver exactly to the objectives of the Government and local communities.

The Almshouse Association would like to see almshouse charities recognised as Community Housing in this aspect of planning. Almshouse charities are led by local trustees drawn from the local community. They provide homes for the local community and are charities where no profit is taken. They are exempt from the right to buy – so remain in perpetuity for local people in housing need. Almshouse charities should be considered for Rural Exception Sites.

We are also seeking views on whether changes are needed to the definition of ‘affordable housing for rent’ in the Framework glossary, to make it easier for organisations that are not Registered Providers, for example community-led developers and almshouses, to develop new affordable homes. This is intended to inform our approach to National Development Management Policies. Please see question 57 below and a possible response:

Question 57 – Do you have views on whether the definition of ‘affordable housing for rent’ in the Framework glossary should be amended? If so, what changes would you recommend?

Answer 57: The Almshouse Association would like to see a change to the definition of affordable housing for rent to include almshouse charities registered with The Charity Commission and by definition provide affordable housing to those in need.

As the definition is drafted in its current form almshouse charities (not Regulated Housing Providers) are not only excluded from accessing Section 106 opportunities but are in some cases required to pay a Section 106 levy when they do expand provision of affordable housing.

The Almshouse Association would like to see the following included in the NPPF definition of affordable housing:

Affordable housing

Housing for sale or rent (including housing made available to residents who are Charity Beneficiaries as LICENSEES), for those whose needs are not met by the market (including housing that provides a subsidised route to home ownership and/or is for essential local workers); and which falls within one or other of the following definitions:

  1. Affordable housing for rent: 

EITHER

(i)  meets all the following conditions:

(a) the rent is set in accordance with the Government’s rent policy for Social Rent or Affordable Rent or is at least 20% below local market rents (including service charges where applicable).

(b) the landlord is a Registered Provider, except where it is included as part of a Build to Rent scheme (in which case the landlord need not be a Registered Provider); and

(c) it includes provisions to remain at an affordable price for future eligible households, or for the subsidy to be recycled for alternative affordable housing provision. For Build to Rent schemes, affordable housing for rent is expected to be the normal form of affordable housing provision (and, in this context, is known as “Affordable Private Rent”).

OR      

      (ii)  the landlord is an almshouse charity operating under the agreed code of practice, registered with the charity commission for England and Wales offerin­g housing as almshouses to persons in need in return for a weekly maintenance contribution equivalent to a social rent or an affordable rent.”

Thank you so much for your help. You have already been a great support and I hate to ask for more help, particularly when so many of you are so busy. Please use any of our responses to other questions (in the briefing paper enclosed) and in the attached letter template to your MP.  

We will keep you advised of progress.

Best regards

Nick Phillips
CEO of The Almshouse Association

posted 10 September 2024