Local Plan Regulation 18 - Affordable housing

Policy HO3
Affordable housing

Housing development should increase the supply and improve the mix of affordable housing to help achieve more sustainable communities in the borough.

1. For developments of 10 or more self-contained dwellings, and on sites with the capacity for 10 or more such dwellings, affordable housing should be provided in line with the following:

a) a strategic borough and London Plan target that at least 50% of all dwellings built are affordable

b) the Threshold Approach to Applications as set out in the London Plan

c) a tenure split whereby 70% of affordable housing is provided as Social Rent and 30% as a range of intermediate housing; and

d) affordable dwellings are distributed throughout the development and not concentrated in a single location on the site.

In negotiating for affordable housing in a proposed development, the council will seek the maximum reasonable amount of affordable housing and take into account:

  • site size and site constraints.
  • financial viability, applying the principles of the Threshold Approach to Applications as set out in the London Plan and the Mayor's Affordable Housing and Viability SPG
  • individual circumstances and characteristics of the site.
  • site specific infrastructure.
  • availability of public subsidy; and
  • CIL charge.

2. Planning applications for developments of 10 or more self-contained dwellings, and with the capacity for 10 or more such dwellings, will be eligible to follow the Fast Track Route of the threshold approach set out in the London Plan where they:

a) meet or exceed the relevant threshold level of affordable housing on site without public subsidy.

b) are consistent with the relevant tenure split within this policy

c) meet all of the other relevant London Plan and Local Plan policy requirements and obligations; and

c) demonstrate that they have taken account of the strategic 50% borough target and have sought grant to increase the level of affordable housing.

For the avoidance of doubt, in circumstances where the four requirements set out immediately above are satisfied, the council will regard that affordable housing provision as "the maximum" reasonable amount of affordable housing.

In exceptional circumstances, a financial contribution may be required to provide affordable housing off-site where other sites may be more appropriate or beneficial in meeting the borough's identified affordable housing needs.

In addition, there should be no net loss of social/affordable rented housing as part of any development proposals.

The affordable housing requirement will apply to all forms of conventional housing in the C3 use Class, purpose-built student accommodation and where appropriate, specialist housing. Specific requirements for these accommodation types are set out in Policies HO6 (Meeting Needs of People Who Need Care and Support) and HO8 (Student Accommodation). Build to Rent and Large-Scale Purpose-Built Shared Living homes have their own particular affordable housing requirements. The requirements are set in Policies HO11 (Large-Scale Purpose-Built Shared Living) and HO12 (Build to Rent).

3. Development proposals for new housing delivering between 1 and 9 units must make provision for affordable housing. This includes new housing resulting from new build development, conversions and changes of use.

a) Proposals delivering between 1 and 9 units will provide 20% of the floorspace as affordable housing. Where feasible, such proposals should seek to deliver affordable housing on site. Where it can be demonstrated to the satisfaction of the council that an off-site contribution is acceptable, this will be secured through a payment-in-lieu.

b) Regardless of the delivery mechanism chosen, small-scale residential development unable to deliver the full affordable housing requirement will be required to submit viability evidence that shows the maximum level of affordable housing can be provided.

4. The application of the Vacant Building Credit (VBC) is not appropriate in Hammersmith and Fulham. The use of VBC will only be considered in limited circumstances, where applicants clearly demonstrate there are exceptional reasons why it is appropriate, and all of the following criteria are met:

a) The building is not in use at the time the application is submitted.

b) The building is not covered by an extant or recently expired permission.

c) The site is not protected for alternative land use; and

d) The building has not been made vacant for the sole purpose of redevelopment

Comment

4.23 A key aim of the Local Plan is to meet local housing need by increasing housing supply, particularly the supply of affordable housing. In order to achieve this strategy Hammersmith and Fulham will seek to increase the amount of affordable housing in the borough by setting a strategic affordable housing target of at least 50% of all dwellings. The strategic target is considered to be in line with the London Plan.

Affordable housing threshold

4.24 In order to maximise affordable housing supply, the council will apply the 50% strategic target to schemes providing 10 or more dwellings. In addition, on schemes of 10 or less dwellings that have a maximum combined gross floorspace of more than 1,000 square metres (GIA), the council will also seek for the maximum level of affordable housing where there is considered to be capacity for more units. In determining capacity, the council will take into account London Plan Policy on site optimisation and Local Plan Policy E1. The affordable housing target will apply to where development is proposed incrementally. This includes variations to a planning consent resulting in additional units on the site. Therefore, the affordable housing proportion should be calculated in relation to gross rather than net provision i.e. it should be based on the total number of units proposed in the final development.

4.25 70% of the affordable housing should be low-cost rented homes, as Social Rent; and 30% should be intermediate housing available to households who cannot afford to buy and/or rent market accommodation in the borough.

4.26 Affordable housing should normally be provided on-site for schemes of 10 units above. In exceptional cases where it can be demonstrated that this is not appropriate in terms of the policies in this Plan, it may be provided off-site. A cash in lieu contribution will only be accepted where this would have demonstrable benefits in furthering the affordable housing and other policies in this Plan. It will be ring-fenced and, where appropriate, pooled to secure additional affordable housing either on identified sites elsewhere or as part of an agreed programme for provision of affordable housing.

Small site contributions

4.27 Affordable housing should also be provided on smaller sites, delivering between 1 and 9 new dwellings. Where feasible proposals should seek to deliver this affordable housing on-site. Off-site provision will be secured through a payment in lieu. The council will take into account London Plan Policy on site optimisation and Local Plan Policy E1 to ensure that the maximum amount off affordable housing is provided on both large and smaller sites. Please note, that this initial position will be subject to viability testing prior to the Regulation 19 Local Plan consultation.

4.28 All development proposals will be expected to demonstrate that they have maximised the amount of genuinely affordable housing on-site in contributing to the delivery of the borough's strategic affordable housing target. Applicants are encouraged to seek grant or public subsidy to maximise the provision of affordable housing.

Financial viability

4.29 In line with the London Plan, a threshold approach to viability will be applied in Hammersmith and Fulham. This means that schemes meeting or exceeding the London Plan threshold approach with public subsidy can be 'fast tracked' and are not required to submit detailed viability information. However, to ensure an applicant fully intends to build out the planning consent an early-stage viability review will be triggered if an agreed level of progress on implementation of the development is not made within a specified time period. Thresholds are expected to be regularly reviewed by the London Plan and may therefore change over the course of the plan period.

4.30 It is recognised that in negotiating for affordable housing specific site constraints and financial viability may affect the amount of affordable housing that can be achieved on that site. The council encourages pre-application discussions with applicants which should include information on financial viability appraisals. Where applicants consider there are exceptional circumstances affecting the viability of a scheme and therefore are unable to meet the minimum amount of affordable housing required under the Threshold Approach, this must be justified through the submission of a viability assessment. Proposals providing between 1 and 9 units unable to deliver the full affordable housing requirement will also be required to submit viability evidence that shows the maximum level of affordable housing can be provided. The council will apply the principles and requirements set out in the London Plan and the Mayor's Affordable Housing and Viability SPG when receiving and assessing financial viability appraisals submitted with planning applications and in negotiating Section 106 Agreements, to ensure the maximum reasonable level of affordable housing is provided and that other plan requirements are met.

Design and integration of affordable housing

4.31 Mixed tenure housing developments should be tenure blind, meaning that it should be difficult to spot the difference in the architectural quality of market and affordable properties. It is important for the council to ensure that housing developments are inclusive for all residents. The council recognises that spreading of affordable housing units may not be practical in all schemes. For example, separate service cores may be necessary between private and all affordable housing units in order to maintain affordable service charges and to aid good housing management when locating affordable tenures.

Retention of social rented housing

4.32 In some circumstances it may be appropriate to redevelop social/affordable rented housing in order to improve the quality of the housing stock or to provide a better mix of housing. Where this is appropriate, the local community should be fully involved and there should be no net loss of social/affordable rented housing in terms of numbers of dwellings or habitable rooms provided. For more information on council strategies for retention of social housing please refer to our Defend Council Homes policy and a Family Housing Strategy available on the council website.

4.33 As outlined previously, some parts of Hammersmith and Fulham are very deprived, and other areas have some of the most prosperous neighbourhoods in London. According to the 2019 Index of Multiple Deprivation, the borough ranked 112th out of 317 local authorities in England on the average IMD score[1]. Deprivation is particularly concentrated in the northern parts of the borough, which also have the highest levels of social rented housing. House prices and private sector rents are well above both the London and national averages. As of May 2025, the average house price in the borough was £785,000, making it the fifth highest in London[2]. Rents in the private sector are also high compared to the rest of London. As of May 2025, the average monthly rent in the borough was £2,759. This is significantly higher than the London average and more than double the national average[3]. The very high cost of market housing both for owner occupation and for rent impacts on who can afford to live in the borough. Using the 3.5x earnings as a measure of affordability and average house price data, a household would need an income of £106,400 to purchase a 1-bedroom existing dwelling in the borough. This increases to £134,600 if the dwelling is new build[4].

4.34 Although private sector rents are high in comparison to incomes, they are often more accessible than home ownership. According to the 2021 Census, the number of households in private rented accommodation rose to 29,700 (37%) up from 26,800 (33%). Owner occupation in the borough peaked at 44% in 2001 but has since decreased to 34% according to the latest census[5]. Households living in affordable housing to rent has decreased from 25,100 (31%) in the 2011 Census to 24,231 (30%) in the 2021 Census.[6]

4.35 The analysis of income and housing costs above highlights the very high cost of housing both for owner occupation and private renting in relation to household incomes in the borough. The need for more affordable housing in the borough is demonstrated in the overall affordable need from 21,844 households over the 15-year Local Plan period, as identified by the council's Local Housing Needs Assessment[7]. The LHNA identifies a need over the Local Plan period for 17,200 social rented dwellings and a need for 5,300 intermediate tenure dwellings, including those for shared ownership and intermediate rented tenures.

Vacant building credit

4.36 The council will seek the maximum amount of affordable housing on any development. Vacant Building Credit (VBC) was introduced by Central Government in 2014 to incentivise the redevelopment of disused and vacant buildings on brownfield sites by offering developers a financial credit equivalent to the existing gross floor space when calculating the affordable housing contribution.

4.37 In an area of high affordable housing need, VBC has the potential to decrease the affordable housing supply across the borough and is therefore not appropriate. The aim of the VBC is to incentivise development on brownfield sites, but this is an unnecessary incentive in Hammersmith and Fulham given that all development sites are brownfield, and that housing delivery has been and is likely to remain strong. Applicants looking to justify the application of the VBC will need to clearly demonstrate exceptional circumstances and ensure that they meet all of the criteria listed in the policy.


[1] Deprivation in Hammersmith and Fulham: Analysis of the 2019 Indices of Deprivation data, 2019

[2] ONS, Housing Prices in Hammersmith and Fulham, 2025 – House Prices

[3] ONS, Housing Prices in Hammersmith and Fulham, 2025 – Monthly Rent

[4] Hammersmith and Fulham Local Housing Needs Assessment 2025 – Figure 22: Annual income needed for 1 and 2-bedroom properties at lower quartile prices

[5] Hammersmith and Fulham Local Housing Needs Assessment 2025 - Figure 10: Housing tenure trends for Hammersmith & Fulham (1981 – 2021) and Figure 12: Number of Households in Hammersmith & Fulham by Tenure 1981-2021.

[6] Hammersmith and Fulham Local Housing Needs Assessment 2025 - Figure 10: Housing tenure trends for Hammersmith & Fulham (1981 – 2021) and Figure 12: Number of Households in Hammersmith & Fulham by Tenure 1981-2021.

[7] Hammersmith and Fulham Local Housing Needs Assessment 2025 - Figure 43: Overall need for Affordable Housing 2027-42, including aspiring households able to access affordable home ownership, by property size.


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